Roth 401 conversion to Roth IRA: which 5-year clock applies?

How is the 5-taxable-year period calculated when I roll over a distribution from a designated Roth account to a Roth IRA? When you roll over a distribution from a designated Roth account to a Roth IRA, the period that the rolled-over funds were in the designated Roth account does not count toward the 5-taxable-year period for determining qualified distributions from the Roth IRA. However, if you had contributed to any Roth IRA in a prior year, the 5-taxable-year period for determining qualified distributions from a Roth IRA is measured from the earlier contribution. So, if the earlier contribution was made more than 5 years ago and you are over 59 ½ a distribution of amounts attributable to a rollover contribution from a designated Roth account would be a qualified distribution from the Roth IRA.

What is the URL for that? I cannot find it with a Google search.

"Alan" wrote:

[....] [quoting the IRS Q&A:]

Thanks for that information.

So the 5-year period starts with the earliest "contribution" to any pre-existing regular (non-employer) Roth IRAs. Right?

But I'm curious: is that limited to the earliest __regular__ contribution per se, or can it be an earlier __conversion__ or __rollover__ contribution?

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In any case, if the rollover is the first Roth IRA contribution (there are no other Roth IRAs), the 5-year period starts on 2 Feb 2013 for my example. Right?

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That is for a rollover from a "designated Roth account" per se.

What about a rollover from a "deemed Roth IRA" under a 401(a) plan, for example?

A "deemed Roth IRA" is different from a "designated Roth account".

According to IRS Pub 590 page 54 regarding a "deemed Roth IRA":

"If the separate account or annuity otherwise meets the requirements of an IRA, it will be subject __only_to_IRA_rules__. An employee's account can be treated as a traditional IRA or a Roth IRA."

And on page 62:

"If you roll over an amount from one Roth IRA to another Roth IRA, the

5-year period used to determine qualified distributions __does_not_change__. The 5-year period begins with the first taxable year for which the contribution was made to the __initial_Roth_IRA__."

So, does the 5-year period starts on 1 Feb 2008 for a rollover from a "deemed Roth IRA" under a 401(a) plan to a regular (non-employer's) Roth IRA, regardless of the 5-year ?

Suppose on 2 Feb 2013, I roll over the Roth account into a regular (non-employer's) Roth IRA.

Which 5-year period do I use to determine the taxability of future distributions from the regular Roth IRA of the amount attributable to the rollover: (a) the period starting 1 Feb 2008; or (b) the period starting 2 Feb 2013?

I am not sure whether it is a 401(a) plan or a 401(k) plan. My records are incomplete. I am checking with the employer on that. ===============

5-year period starting 1/1/2008.

[Snip]

Correct. That could include a deemed Roth IRA.

It is my understanding, that the date starts with your first contribution, not a conversion.

It starts 1/1/13 if you are asking about a designated Roth IRA, not a deemed Roth IRA.

The answer is above. A deemed Roth IRA is a Roth IRA, not a designated Roth IRA. As such, the date starts 1/1/2008.

[....] [....] [....]

Oh, I see I overlooked a subtlety: the 5-year period begins with the __beginning__ of the taxable year. (Doh!)

Thanks again.

Does your response conflict with Alan's? I don't understand the phrase "the period that the rolled-over funds were in the designated Roth account does not count toward the 5-taxable-year period for determining qualified distributions from the Roth IRA".