A father contributes to a Roth IRA for his 15-year-old child, who had a summer job. The father names himself as custodian. The father can withdraw from the IRA for the exclusive benefit of the minor child. The contribution is not “unwithdrawable” until the child is 21. Is this sufficient to make the contribution a present interest gift for the gift tax.

If the father dies before the minor is 21, then is the IRA balance in the father’s estate, as would be the case under UTMA, where the donor is the custodian? If so, then would have the mother be the custodian for the IRA and the father be the donor keep it out of their estates if either or both dies before the kid turns 21?