Penalty free rollovers from 529 accounts to Roth IRAs

If a child is graduating with money left over in his Coverdell, but not yet earning qualified income, will this new rule be of any use? It looks like the answer is “no”. Am I missing something?
SEC. 126. SPECIAL RULES FOR CERTAIN DISTRIBUTIONS
5 FROM LONG-TERM QUALIFIED TUITION PRO6 GRAMS TO ROTH I



You are correct. An ESA is not a qualified tuition program, and an ESA balance cannot be transferred into a 529 plan and then transferred to a Roth IRA.



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