T-IRA to Roth conversion | Ed Slott and Company, LLC

T-IRA to Roth conversion

Can someone let me know what IRC Section governs the "pro-rata" rule that applies to T-IRA to Roth conversions?

I have an indvidual that is holding strong staing a T-IRA account holder can avoid the pro-rata ruling by establishing multiple IRAs.

Thank you

Sec 408(d)(2) clearly states that all IRA accounts are to be treated as 1 contract. This is also addressed starting on p 40 of Pub 590 and in the instructions for Form 8606.

 

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