I have been getting conflicting opinions on whether a 2010 conversion of funds from a rollover IRA to a Roth IRA counts as part of the MRD for 2010. I am inclined to think that it does not, but cannot find in Pub 590 a definitive statement one way or the other. Help.
A distribution that is an MRD cannot be used to fund any other IRA.
So an MRD cannot be used as a conversion.
If you plan to do a conversion, first take the MRD, then using other IRA moneys, do a conversion.
If you are subject to a RMD in 2010, that amount must be withdrawn prior to making any Roth conversion. Such funds cannot be converted to a Roth. The amount of your RMD is determined by your age/life expectancy factor and the balance in your traditional/rollover IRA on December 31, 2009.
Because of the special waiver of RMDs for 2009, the above rule was not in effect. No such waiver (currently) exists for 2010.
The statement you are looking for is included in the RMD section of Pub 590 (page 33, 2009 edition).
It doesn't because a conversion is not a distribution.
Thanks to all.
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