Roth was rolled over to a Traditional IRA, how to undo?

Several years ago, an Ameriprise advisor rolled our client’s Roth IRA into a Traditional IRA. Is there a way to undo this transaction? What would be required from a tax reporting standpoint, and what information would be needed to effectively undo this transaction?



Several years suggests this occurred in a now closed tax year. Nonetheless, there is no SOL for excess IRA contributions, and as a disallowed rollover, this created an excess regular TIRA contribution subject to annual 6% excise tax plus interest. The excess amount might have been eliminated or partially eliminated by interim years in which client was eligible to make TIRA contributions (deductible or ND) and did not, or by any taxable distributions taken from the TIRA. These distributions or contributions eligible but not made would be reconciled on annual Form 5329 forms, the same ones used to report any excise tax due. They would reduce the outstanding excess amount on which the annual excise tax is based. 
This exact error must be detected ASAP after the disallowed rollover, since the custodians may be willing with sufficient documentation to reconstruct the rollover properly. Once the year of that rollover is over custodians are not going to cooperate unless they were 100% at fault. Plan B would then be to address the excess contributions and remove them before the due dates as typical excess contributions. If that due date also passes, Plan C would be to withdraw the excess after the due date using Sec 408(d)(5), in which a TIRA excess that was not deducted could be removed without tax liability. In this particular case, where the excess was created back in a closed tax year, the client might just as well play the audit lottery and prepare eventually to be double taxed on what were originally Roth contributions.

There should be some remedy if it was the Ameriprise advisor rather than the IRA owner who did this.

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