2020 Roth Conversion Opportunity to Undo

Individual executed a Roth Conversion in late April 2020. Subsequent to doing so had a discussion with CPA who informed the individual that the taxable income from the conversion would cause them to lose their premium subsidy under the Affordable Care Act. The individual wants to know if they can withdraw the amount of the converted Traditional IRA from the Roth IRA account (is under age 59 1/2) without penalty and repay it to the Traditional IRA account using the CARES Act provision for taking up to $100,000 IRA distributions in 2020 and being able to repay later to avoid the income tax. The repayment of the distribution would occur in 2020 thereby avoiding the inclusion of the taxable Roth Conversion amount in income and also avoiding the premium subsidy issue. However, is the fact that the initial transaction was a “Roth Conversion” a deal killer here? The individual definitely was affected by the COVID issue in terms of greatly reduced income from their business. What think you? Thanks.



Also, can some of the amount that was converted be distributed from the Roth IRA account and replaced in the Traditional IRA just to get under the subsidy cliff?



  • While the individual can tap the Roth IRA as a CRD, such a distribution will not help with anything other than liquidity. Conversions can no longer be recharacterized, and a distribution from a Roth IRA cannot be rolled into a TIRA or any form of retirement acccount other than another Roth IRA. Repayment of a CRD taken from the Roth IRA would therefore have to be made to another Roth IRA within the 3 year time span. 
  • If the conversion was done in April and invested in stocks or stock funds, this conversion has already gained more than loss of the ACA subsidy if the conversion amount was large enough. So even if recharacterizations were still allowed, moving Roth gains back into a TIRA and making them eventually taxable would not be a wise long term transaction.


Thank you, Alan!



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