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New conversion to Roth after recharacterization

Three situations: (A) T converts the entire amount of traditional IRA to Roth in 2010; recharacterizes a portion in October 2011. As I understand the Section

408A rules, T may not do another conversion prior to 2012. (B) Same as (A), but T also has a 401(k) plan with Roth feature. Can T do either an in-plan conversion or a conversion to a Roth IRA in 2011, notwithstanding the prohibition of Section 408A? (C) T converts a portion (say, $20,000) of his $55,000 traditional IRA to Roth in 2010; recharacterizes some of it in October 2011 (say, $5,000). The traditional IRA now has $40,000 in it. Can T convert up to $35,000 of the traditional IRA to a Roth in 2011 (i.e. the $5,000 recharacterized amount remains in the account), or are all conversions prohibited prior to 2012?
Reply to
Tom Healy CPA
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True.

Yes. Different account... different amount.

T can convert that part of the traditional IRA that was not involved in the original conversion.

Also note that if T has already filed a timely 2010 tax return, there are a few steps that have to be taken to get the extension to 10/15/11. See

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for information on how one gets the extension to 10/15 if one has already filed.

Reply to
Alan

I believe he can do a re-conversion after 30 days, since 2011 is "the taxable year following the taxable year in which the amount was converted to a Roth IRA...regardless of whether the recharacterization occurs during the taxable year in which the amount was converted to a Roth IRA or the following taxable year".

See Sec. 1.408A-5:

"Q?9. If an IRA owner converts an amount from a traditional IRA to a Roth IRA and then transfers that amount back to a traditional IRA in a recharacterization, may the IRA owner subsequently reconvert that amount from the traditional IRA to a Roth IRA?

"A?9. (a)(1) Except as otherwise provided in paragraph (b) of this A?9, an IRA owner who converts an amount from a traditional IRA to a Roth IRA during any taxable year and then transfers that amount back to a traditional IRA by means of a recharacterization may not reconvert that amount from the traditional IRA to a Roth IRA before the beginning of the taxable year following the taxable year in which the amount was converted to a Roth IRA or, if later, the end of the 30-day period beginning on the day on which the IRA owner transfers the amount from the Roth IRA back to a traditional IRA by means of a recharacterization (regardless of whether the recharacterization occurs during the taxable year in which the amount was converted to a Roth IRA or the following taxable year). "

[...]

This is right in Pub 590 too.

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Reply to
Mark Bole

You are correct. I forgot the OP said it was a 2010 conversion. He can convert on the 31st day or later.

Reply to
Alan

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