The suspension of misc itemized deductions subject to the 2% AGI floor has made the payment of advisory and administrative fees directly from pre tax retirement accounts very popular. However, “wealth plan” suggests a broad scope, perhaps even estate planning, that never was deductible as a misc deduction. Permissable costs that can be deducted directly from a pre tax IRA are limited to the administrative fees and investment advisory fees for pre tax IRAs. Such fees for any Roth IRA or employer plan cannot be deducted from a TIRA, therefore the bill the IRA custodian receives should be limited to the advisory or administrative portions of the total fee and then pro rated relative to the TIRA balance vs other retirement plans. If this is done, there is no constructive contribution or distribution from the IRA and no 5498 or 1099R issued. I suspect that there is little underwriting being done by IRA custodians to determine if the IRA is being billed for expenses that are not allowed under the tax code.

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