Roth Record Keeping

The source of my Roth account comes from several factors:
1. Annual contributions
2. A one-time (rollover) from my employer’s after-tax 401K saving plan to Roth (i.e. non taxable event)
3. Several yearly Roth conversions from my (fully deductible) traditional IRA (i.e. taxable events w/Form 8606 filed)
4. Investment gains
What documentation does the IRS suggest/require that I (and potential beneficiaries) maintain to ensure future Roth withdrawals are non-taxable if challenged?



The IRS addresses this on p 6 of the 8606 Instructions, but their advice is overkill in some respects and falls short in others. It takes a consistent effort to maintain a Roth IRA basis file every year, but once your Roth is qualified (5 years and 59.5) you can toss all the prior documentation and just retain some evidence such as a 5498 for a year at least 5 years old. Note that the IRS almost never requests that a taxpayer prove their Roth basis, but they could conceivably start at some point.
For regular Roth contributions, keep the 5498 forms each year. But if you made a contribution that you had returned (excess) or recharacterized as a TIRA contribution, make a notation of that on the 5498, since either of those actions erases that contribution.
For rollovers from your 401k, keep the 1099R you receive (make a copy for your Roth file). This will show the year of the rollover and the taxable portion in Box 2a.
For your conversions, keep the 8606 reporting each conversion
For investment gains, NO documentation is required. All you need to track is regular and conversion basis. Gains only come into play after all your basis has been distributed and there is still a balance remaining.
I see no need to keep your 1040 any longer than you otherwise would (7 years in most cases).
All your beneficiaries need to know is the first year you made any type of Roth IRA contribution.  Once you reach 5 years, all distributions to beneficiaries are completely tax free and they do not have to file an 8606 to report distributions including RMDs.
Again, once your Roth becomes qualified you can purge most of the above records. DIstributions you take after that will not need an 8606.

I am over 59 1/2 and my Roth IRA has been open for over 5 years. I stopped contributing over 5 years ago. Following are my questions:1. Do I need to retain any tax records?2. Are tax free withdrawals reported to the IRS?3. Do I need to report tax free withdrawals on my tax return?3. Can any future tax free withdrawals be challenged by the IRS? 

At this point, all you need to keep is documentation that any contribution you made was prior to 2018, or 2017 if you plan a distribution before year end. That documentation could be a Form 5498 showing your contribution, either regular or conversion, or an IRA account statement showing a Roth IRA contribution or balance in some year prior to 2018. You do not need to retain anything else.
You still must report distributions on line 4a of your 1040, but Form 8606 is not needed once your Roth becomes qualified. 4b is the taxable line, so will be blank.
For future highly unlikely IRS challenges, they have all your 5498 forms and they know your age, and I have not heard of any cases where they challenged the 5 year holding period. That said, if all your contributions were excess contributions, the 5 year clock does not start. For example, if your modified AGI was too high for a Roth contribution for every one of those contributions, your 5 year clock never started unless you did a conversion. That said, if you have several aged excess contributions, you could be subject to the 6% excise tax to apply to these contributions every year after the excess was made and not removed, and that would be an even more serious problem. 

Alan, thanks for the reply.

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