CARES act

It appears the CARES act allows an IRA distribution of up to $100,000 and spread tax or 3 yrs. could this be used for Roth conversion strategy, example: convert $100,000 of TIRA to RIRA and spread the tax over 3 yrs.



It does not appear so, since a Roth IRA is not an eligible plan to which a CV related distribution can be rolled. However, the distribution could be rolled back to a TIRA, and then converted in a normal conversion in which the income would all have to be reported in the conversion year. Therefore, the 2010 income split over 3 years is not available for a CV distribution.



a 401k particpant takes a CRD distirbution of $100(k) and subsquently (same year) rolls into a T-IRA In essence it would like an in-service rollover.  Would this be considered a rollover and thus not be subject to income taxes? Thx 



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