RMDs and Roth Conversions

Submitted by Amanda Minter on Mon, 2020-12-21 18:32

Two questions:
1 – where in the IRS rulings would I find that the first dollars distributed from a Traditional IRA will be labeled RMD?

2 – where in the IRS rulings would I find that you can not convert your RMD to a Roth?

Permalink Submitted by Alan - IRA critic on Mon, 2020-12-21 18:51

See IRS Reg 1.402(c)(2), Q&A 7 states that the first distributions from an account in an RMD distribution year are treated as the RMD, and therefore are not eligible for rollover. Link below:
26 CFR § 1.402(c)-2 – Eligible rollover distributions; questions and answers. | CFR | US Law | LII / Legal Information Institute (cornell.edu)
Since such distributions cannot be rolled over, they also cannot be converted since a conversion is treated as a rollover.

Permalink Submitted by David Mertz on Mon, 2020-12-21 19:17

Additionally, 26 U.S. Code § 408A(3)(C) defines a Roth conversion as a distribution and rollover and 26 CFR § 1.402(c)-2 Q&A-3 is the regulation that says that an RMD is not eligible for rollover
https://www.law.cornell.edu/uscode/text/26/408A