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Roth Conversion Rules FAQ

After the recent article “Roth Conversion Planning, a Step-by-Step Approach,” it has become clear through emails from readers that lots of people have questions — not just about the decision making process, but about the rules themselves. So what follows is a brief FAQ about the rules surrounding Roth conversions.

Is there an income limit for Roth conversions?

No. There used to be a limit. (Prior to 2010, you could not do a Roth conversion if your modified adjusted gross income exceeded $100,000.) But there is no longer an income limit.

Is there an income requirement for a Roth conversion?

No. While you (or your spouse) must have earned income in order to make a Roth IRA contribution, you do not have to have any earned income in order to do a Roth conversion.

Is there a maximum amount you can convert per year?

No. There is no maximum conversion — other than the fact that you can’t convert more than you have in tax-deferred accounts.

Can you do a partial conversion, or do you have to convert the whole account at once?

You can do a partial conversion of a traditional IRA. For example, converting $20,000 of a $100,000 account is perfectly allowed.

And in most cases in which conversions make sense, doing partial conversions over a period of years is in fact what’s most desirable — converting only enough to put your income up to a particular threshold each year, rather then converting the whole account at once. Converting the whole account at once would often mean paying a high tax rate on the conversion, as it would mean having a very high level of income that year. (Of course, this depends on the size of the account.)

Note that the same is true for a 401(k). If your 401(k) allows for in-plan conversions, you can do a partial conversion to Roth 401(k).

How is a Roth conversion (from a traditional IRA) taxed?

Generally, a Roth conversion will be taxable as ordinary income.

If, however, you have made nondeductible contributions, a portion of the conversion will not be taxable. Specifically, the percentage of the conversion that is not taxable is calculated as:

  • Your basis in traditional IRAs, divided by
  • The sum of your traditional IRA balances on 12/31 of the year of the conversion and any distributions and conversions from traditional IRAs that occurred that year.

Your basis in traditional IRAs is the sum of your nondeductible contributions, minus any portions of those amounts that have been distributed or converted.

For example, if you have made $20,000 of nondeductible contributions over the years (and none of those amounts have been distributed or converted), you have $20,000 of basis in your traditional IRAs. If you do a $100,000 conversion, and at the end of the year your traditional IRAs are in total worth $400,000, then 4% of your $100,000 conversion would be nontaxable.

That is, $20,000 (basis in traditional IRAs) divided by $500,000 (i.e., the sum of the conversions/distributions for the year and the sum of your traditional IRA balances at the end of the year) equals 4%. So you would have $96,000 of gross income as a result of the $100,000 conversion.

Something that surprises many people is that if, for example, you do a Roth conversion in March and then in November of the same year you roll a 401(k) into a traditional IRA, that rollover is going to affect the portion of the conversion that’s taxable (because it will increase your traditional IRA balance on 12/31 of that year).

Another key point here is that all of your traditional IRAs (including SEP and SIMPLE IRAs) are considered to be a single IRA for the purpose of this calculation. (See: “When are IRAs Aggregated?”)

How is an in-plan Roth conversion (e.g., a conversion within a 401(k)) taxed?

As with a conversion of a traditional IRA, the conversion will generally be taxable. Also similarly, if you have made nondeductible, non-Roth (i.e., “after-tax”) contributions to the plan, a portion of the conversion will be nontaxable. And again, it’s a pro-rata calculation.

However for this calculation, unlike with IRAs, the 401(k) is not aggregated with other 401(k) plans.

Also, if the plan separately accounts for the after-tax contributions and their earnings, then it’s possible to largely avoid the pro-rata rule, because you can have just those amounts (i.e., the after-tax contributions and their earnings) converted. In such a case you would only have to pay tax on the earnings on the after-tax contributions.

Can a Roth conversion trigger the 10% penalty?

If you are under age 59.5, any money that comes out of the traditional IRA and does not end up going into the Roth IRA may be subject to the 10% penalty. For instance, if you take $100,000 out of your traditional IRA, $75,000 goes into your Roth IRA, and $25,000 is withheld to pay the tax on the conversion/distribution, the $25,000 would be subject to the 10% penalty if you’re under age 59.5 and don’t meet one of the other exceptions to the penalty.

When is a Roth conversion taxed?

A Roth conversion is taxable in the year in which it occurs. That is, conversions work on a calendar-year basis. There’s no “I’m doing this in March of 2022, and I want it to count for 2021” option as there is for contributions to an IRA.

How are distributions from a Roth IRA treated, after a conversion?

When amounts that were converted to a Roth IRA are distributed from the Roth IRA, they will not be subject to ordinary income tax. They might be subject to a 10% penalty. But that penalty will not apply if you’re at least age 59.5, or if the conversion was at least 5 years ago, if the conversion itself wasn’t taxable, or if one of several other exceptions applies. For more details, see “Roth IRA Distribution Rules” or the Roth IRA Distribution Tool.

Can I do a Roth conversion of an inherited IRA?

No — unless you inherited it from your spouse, in which case you’re allowed to treat the account as your own, which allows you to do a conversion into your own Roth IRA.

Can I recharacterize (undo) a Roth conversion?

No. As a result of a change made by the Tax Cuts and Jobs Act of 2017, you can no longer recharacterize a Roth conversion.

Does a Roth conversion satisfy my RMD for the year?

No. If you have to take a required minimum distribution (RMD) in a given year, a Roth conversion does not count toward that RMD.

Roth IRA Withdrawal Rules

Mike’s note: In talking to people about Roth conversions, it has become clear to me that people have a lot of misunderstandings about the general rules for Roth IRA distributions. So today’s article is something of a back-to-basics post.

Types of Roth IRA Distributions

Withdrawals from a retirement account are known as “distributions.” The way a distribution from a Roth IRA is taxed depends on what type of money is being distributed. Specifically, a Roth IRA can consist of (up to) three types of money:

  1. Contributions,
  2. Amounts converted from a traditional IRA or other retirement plan, and
  3. Earnings.

An important point to note here is that earnings are not considered to be “earnings on contributions” or “earnings on converted amounts.” They’re simply earnings.

Example: In Year 1 Kevin contributes $6,000 to a Roth IRA. In Year 2 Kevin contributes another $6,000 to the Roth IRA. He also converts $30,000 from his traditional IRA to his Roth IRA. At the end of Year 2, Kevin’s Roth IRA is worth $50,000. That $50,000 is considered to be a) $12,000 of contributions, b) $30,000 from conversions, and c) $8,000 of earnings. It does not matter whether the earnings are the result of growth from the converted amounts or growth from the contributed amounts. Earnings are simply earnings.

Another important point here is that distributions from a Roth IRA are considered to happen in the order listed above. That is, distributions are considered to first come from contributions, then from converted amounts, then from earnings.

Distributions of Contributions

The tax treatment of distributions of contributions is simple: contributions can come out at any time, tax-free and penalty-free.

Example: Kelly is 24 years old. She opens her first Roth IRA and contributes $3,000. Two weeks later, she takes the $3,000 back out. Kelly does not owe any tax or penalty.

Distributions of Converted Amounts

Distributions of converted amounts are not subject to ordinary income tax.

Distributions of converted amounts are subject to a 10% penalty, unless (at least) one of the following is true:

  • The distribution is occurring at least 5 years from January 1 of the year in which the conversion occurred,
  • The distribution is of a converted amount that was not taxable in the year of the conversion,
  • The distribution is for a “qualifying reason” (listed below), or
  • One of the “other exceptions” to the 10% penalty (also listed below) applies.

Distributions of converted amounts are considered to occur on a first-in-first-out basis. That is, if you do a Roth conversion in Year 1 and another in Year 2, distributions will be considered to come from the Year 1 conversion first. And for a given conversion, if it was partially taxable and partially nontaxable, the taxable portion (i.e., the portion of the conversion that was taxable in the year of conversion) is considered to be distributed before the nontaxable portion.

Qualifying Reasons

The following are the “qualifying reasons” for a distribution from a Roth IRA:

  • You have reached age 59½.
  • The distribution was made to your beneficiary after your death.
  • You are disabled.
  • You use the distribution to pay certain qualified first-time homebuyer amounts.

Other Exceptions to 10% Penalty

The following are the “other exceptions” to the 10% penalty:

  • The distributions are part of a “series of substantially equal payments.”
  • You have unreimbursed medical expenses that exceed 7.5% of your adjusted gross income.
  • You are paying medical insurance premiums during a period of unemployment.
  • The distributions are not more than your qualified higher education expenses.
  • The distribution is due to an IRS levy of the account.
  • The distribution is a qualified reservist distribution.
  • The distribution is a qualified birth or adoption distribution (up to $5,000 per parent per birth/adoption).
  • The distribution was a “qualified coronavirus-related distribution.”

Distributions of Earnings

Distributions of earnings will be subject to ordinary income tax unless they are “qualified distributions.” In order for a distribution to be a qualified distribution:

  • It must be for a “qualifying reason” (listed above), and
  • The distribution must not occur any earlier than 5 years from January 1 of the year in which you first established and contributed to a Roth IRA. (For example, if you first opened and contributed to a Roth IRA on May 18, 2019, this 5-year rule would be satisfied as of January 1, 2024.)

And distributions of earnings will be subject to a 10% penalty unless:

  • The distribution is for a “qualifying reason” (listed above), or
  • You meet one of the “other exceptions” to the 10% penalty (also listed above).

The following flowchart summarizes tax treatments of distributions of earnings from a Roth IRA:

All Roth IRAs Are Viewed as One

When applying the above rules, the IRS views all of your Roth IRAs together as one big Roth IRA. For example, distributions from a Roth IRA will not count as distributions of earnings until you’ve withdrawn an amount greater than the total of all of your contributions to all of your Roth IRAs.

Example: In 2018, you contributed $2,000 to a Roth. In 2019, you opened a Roth IRA with a different brokerage firm and contributed $3,000 to it. By 2021, each Roth has grown to $5,000. You could withdraw $5,000 from either (but not both) of the two Roth IRAs without having to pay taxes or penalties because your total contributions were $5,000 and because the IRS considers them to be one Roth IRA for these purposes.

What if You Have Rolled a Roth 401(k) or 403(b) into Your Roth IRA?

If you have rolled assets from a designated Roth account in an employer plan (i.e., what we would typically refer to as a Roth 401(k) or Roth 403(b)) into your Roth IRA, those rollover amounts are separated into contributions and earnings — and then lumped into the appropriate category along with regular Roth IRA contributions and earnings.

Of note: at least in theory, this information should be transmitted from the administrator of the employer plan to the administrator of the Roth IRA. But it’s best if you keep records of your own, to be able to demonstrate the portion of the rollover that is attributable to contributions.

Example: Over the course of a few years, you contribute $50,000 to your Roth 401(k). After leaving that employer, you roll the entire Roth 401(k), which is worth $80,000 at the time of the rollover, into your Roth IRA. For the sake of applying the distribution rules discussed above, the $50,000 is treated as if it were regular Roth IRA contributions (i.e., it can be withdrawn from the Roth IRA tax-free and penalty-free at any time). And the additional $30,000 will be treated just like any other earnings in the Roth IRA (i.e., it will be treated in keeping with the rules shown in the flowchart above).

What is a Rollover IRA? (Rollover IRA vs. Traditional IRA)

A reader writes in, asking:

“At my primary brokerage firm I have two IRAs: a traditional IRA and a rollover IRA that holds assets that came from my prior employer’s 401-k plan. What is the difference between the two?”

“Rollover IRA” is just a subcategory of “traditional IRA.” In other words, a rollover IRA is a traditional IRA. Specifically, rollover IRAs are traditional IRAs that contain nothing but assets that came from an employer-sponsored plan.

Because a rollover IRA is a traditional IRA, it gets all the same tax treatment as a normal traditional IRA. That is, distributions from the account are generally taxable; you can do a Roth conversion of the assets in the account; it’s treated the same way with regard to aggregation rules as other traditional IRAs; and so on.

Rollover IRAs are designated as such (rather than just being called regular traditional IRAs) for two reasons.

Reason #1: some employer plans only accept rollovers from an IRA when the IRA contains only assets from another employer-sponsored plan. So keeping those assets separate in their own IRA (rather than combining them with other assets in a traditional IRA) could preserve your ability to roll those assets into a different employer plan at a later date. But fewer and fewer employer plans have this policy every year, so this distinction is becoming less relevant.

Reason #2: assets in an employer-sponsored plan have unlimited creditor protection in bankruptcy under federal law. In contrast, IRA assets are only protected up to a certain limit ($1,362,800 as of 2020). If assets from an employer-sponsored plan are rolled into an IRA and kept separate (i.e., kept in a separate “rollover IRA”), they continue to receive that unlimited protection. If the assets get commingled with other assets in a traditional IRA, then they might lose that unlimited protection and “only” be protected up to the $1,362,800 limit.

That said, some people make the case that if you have good records and could prove that the assets in question came from an employer plan, you would still have unlimited protection for those assets. Also, many states provide additional protection to IRA assets beyond what federal law provides. And of course most people’s IRA assets are never going to exceed the federal protection limit anyway.

To summarize, a rollover IRA is a traditional IRA and is taxed as such, but there are two reasons for keeping rollover IRA assets separate from other traditional IRA assets. It may well be the case, however, that neither of those two reasons is particularly applicable to your own circumstances.

When Are IRAs Aggregated?

A reader writes in, asking:

“I have read that your traditional IRAs are all considered one IRA as far as the IRS is concerned. But I recently found another article that explicitly indicated otherwise. Maybe it depends on circumstances? Could you elaborate on this in an article?”

The issue is not so much that it depends on circumstances, but rather that IRAs are aggregated for some purposes and not for other purposes.

Traditional IRAs Aggregated for RMDs

For RMD purposes, all of your traditional IRAs will be treated as if they are one collective traditional IRA. Specifically, each traditional IRA will have its RMD calculated separately, but then you can total up all your necessary traditional IRA RMDs for the year and take that total amount out of any one traditional IRA or any combination of traditional IRAs.

Note that SEP IRAs and SIMPLE IRAs count as traditional IRAs here, so they are aggregated as well.

Employer-sponsored plans are not aggregated with your IRAs though (nor are they aggregated with each other). For example, a distribution from your 401(k) will not count toward satisfying your traditional IRA RMD for the year.

Traditional IRAs Aggregated for Distribution/Conversion Taxability

Similarly, when you take a distribution from a traditional IRA — or do a Roth conversion from a traditional IRA — whether or not it is taxable will depend on an aggregated calculation.

Example: Joan has made $20,000 of nondeductible contributions to her traditional IRA at Vanguard. During 2020, Joan makes a $40,000 Roth conversion from that IRA. At the end of the year, the balance in Joan’s Vanguard traditional IRA is $100,000. She also has a traditional IRA at Schwab with a year-end balance of $60,000. She has taken no other distributions (or done any other conversions) from these IRAs.

The nontaxable portion of Joan’s conversion is calculated as her basis in traditional IRAs (i.e., the amount of nondeductible contributions she has made), divided by the sum of her year-end balances and distributions or conversions from traditional IRAs over the course of the year. (And again, we’re counting all of her traditional IRAs here.)

Joan’s basis is $20,000. The sum of her year-end traditional IRA balances is $160,000. And the sum of her conversions and other distributions from traditional IRAs for the year is $40,000. So the nontaxable portion of Joan’s conversion is calculated as: $20,000 / ($160,000 + $40,000) = 10%. In other words, 90% of Joan’s conversion will be taxable.

IRAs Not Aggregated for “SEPP” Distributions

IRAs are not aggregated for the “series of substantially equal periodic payments” rule, sometimes referred to as 72(t). For that purpose, each traditional IRA is treated as its own separate account.

Aggregation for Roth IRA 5-Year Rule

With regard to the 5-year rule for distributions of earnings from Roth IRAs, once you have satisfied the 5-year rule for one Roth IRA, you have satisfied it for all Roth IRAs.

Inherited IRAs Not Aggregated

Inherited IRAs are not aggregated with other IRAs for RMD purposes, nor are inherited IRAs aggregated with other IRAs for the purpose of calculating what portion of a distribution (or conversion) is taxable.

Inherited IRAs can be aggregated with each other for RMD purposes if the inherited IRAs in question a) were originally owned by the same person and b) are being distributed over the same period (i.e., if the inherited IRAs are being distributed over somebody’s life expectancy, it must be the same life expectancy that is being used for each inherited IRA if you want to aggregate them with each other for RMD purposes).

Inherited IRA Rules (Updated for 2020 to Reflect SECURE Act and CARES Act)

As a result of the SECURE Act that was passed in late 2019, there are now essentially two sets of rules for inherited IRAs. Which rules to use depends on a) when the original account owner died and b) who is listed as the beneficiary of the account.

Also, as a result of the CARES Act that was passed in March 2020, there are no required distributions for 2020 from IRAs — whether inherited or not.

Death in 2020 or Later

If the IRA owner dies in 2020 or later, we first have to determine whether the beneficiary is an “eligible beneficiary.”

Eligible beneficiaries include:

  • the surviving spouse of the original account owner,
  • a minor child of the original account owner,
  • anybody who is disabled or chronically-ill (per the definition found in IRC 7702B(c)(2)), or
  • any designated beneficiary who is not more than 10 years younger than the original account owner.

If the beneficiary is an eligible beneficiary, then the old rules apply (see below).

If the beneficiary is not an eligible beneficiary, the new rule applies. And the new rule simply says that the account must be completely distributed within 10 years of the original owner’s death. The distributions do not, however, have to occur evenly over those 10 years. (For instance, if you wanted to do so, you could take no distributions for the first 9 years, then distribute everything in year 10.)

Deaths in 2019 or Earlier, As Well as Eligible Beneficiaries

The “old rules” discussed in the remainder of this article apply in situations in which either:

  • The IRA owner died in 2019 or earlier, or
  • The beneficiary is an “eligible beneficiary” as described above, and therefore able to use the (more favorable) old rules.

Under the “old rules,” there are still actually two sets of rules: one set of rules that applies if the deceased owner was your spouse, and another set for any other designated beneficiary. We’ll cover spouse beneficiaries first, then non-spouse beneficiaries, then situations in which there are multiple beneficiaries.

Inherited IRA: Spouse Beneficiary

As a spouse beneficiary, you have two primary options:

  1. Do a spousal rollover — rolling the account into your own IRA, or
  2. Continue to own the account as a beneficiary.

Note: there’s no deadline on a spousal rollover. Should you want to, you can own the account as a spousal beneficiary for several years, then elect to do a spousal rollover.

If you do a spousal rollover, from that point forward it’s just a normal IRA (i.e., it’s just like any other IRA that was yours to begin with), so all the normal IRA rules apply, whether Roth or traditional.

If you continue to own the account as a spousal beneficiary, the rules will be similar to normal IRA rules, but with a few important exceptions.

No 10% Penalty
First, you can take distributions from the account without being subject to the 10% penalty, regardless of your age. So if you expect to need the money prior to age 59.5, this is a good reason not to go the spousal rollover route — at least not yet. (As mentioned above, there’s no deadline on a spousal rollover.)

Withdrawals from Inherited Roth IRA
Second, if the inherited account was a Roth IRA, any withdrawals of earnings taken prior to the point at which the original owner would have satisfied the 5-year rule will be subject to income tax (though not the 10% penalty).

Spouse Beneficiary RMDs
Third, you’ll have to start taking required minimum distributions (RMDs) in the year in which the deceased account owner would have been required to take them. (If the original owner — your spouse — was required to take an RMD in the year in which he/she died, but he/she had not yet taken it, you’re required to take it for him/her, calculated in the same way it would be if he/she were still alive.)

Your RMD from the account will be calculated each year based on your own remaining life expectancy from the “Single Life” table in IRS Publication 590-B.**

Inherited IRA: Non-Spouse Beneficiary

When you inherit an IRA as a non-spouse beneficiary, the account works much like a typical IRA, with three important exceptions.

No 10% Penalty
Distributions from the account are not subject to the 10% penalty, regardless of your age. (This is the same as for a spouse beneficiary.)

Withdrawals from Inherited Roth IRA
If the inherited account was a Roth IRA, any withdrawals of earnings taken prior to the point at which the original owner would have satisfied the 5-year rule will be subject to income tax, though not the 10% penalty. (This is also the same as for a spouse beneficiary.)

Non-Spouse Beneficiary RMDs
Each year, beginning in the year after the death of the account owner, you’ll have to take a required minimum distribution from the account. (If the account owner was required to take an RMD in the year of his death but he had not yet taken one, you’ll be required to take his RMD for him, calculated in the same way it would be if he were still alive.)

The rules for calculating your RMD are similar (but not quite identical) to the rules for a spousal beneficiary. Again, your first RMD from the account will be calculated based on your own remaining life expectancy from the “Single Life” table in IRS Publication 590-B. However, in following years, instead of looking up your remaining life expectancy again (as a spousal beneficiary would), you simply subtract 1 year from whatever your life expectancy was last year.**

For example, imagine that your father passed away in 2018 at age 65, leaving you his entire IRA. For 2018 (the year of death), you have no RMD. On your birthday in 2019, you turn 30 years old. According to the Single Life table, your remaining life expectancy at age 30 is 53.3 years. As a result, your RMD for 2019 would have been equal to the account balance as of 12/31/2018, divided by 53.3.

For 2020, if it weren’t for the CARES Act eliminating RMDs for 2020, your RMD would have been equal to the account balance at the end of 2019, divided by 52.3. (But because of the CARES Act, the RMD for 2020 would be zero.) In 2021, the RMD will be the 12/31/2020 balance, divided by 51.3.

Important exception: if you want, you can elect to distribute the account over 5 years rather than over your remaining life expectancy. If you elect to do that, you can take the distributions however you’d like over those five years — for example, no distributions in years 1-3 and everything in year 4.

Successor Beneficiary RMDs
If a beneficiary dies before the account has been fully distributed, the new inheriting beneficiary is known as a successor beneficiary.

If the original account owner died in 2020 or later and the original beneficiary (i.e., the first person to inherit the IRA) was a “non-eligible” beneficiary, then the successor beneficiary will have to keep using the same distribution schedule. That is, the successor beneficiary will have to distribute the account within 10 years of the original owner’s death.

Conversely, if the original account owner died before 2019 and/or the original beneficiary was an “eligible” beneficiary, then the successor beneficiary will have to distribute the account over 10 years, but it’s a new 10-year period, beginning with the date of the original beneficiary’s death (rather than beginning with the date of the original owner’s death).

Tips for Non-Spouse Beneficiaries

  1. When you retitle the account, be sure to include both your name and the name of the original owner.
  2. Name new beneficiaries for the account ASAP.
  3. If you decide to move the account to another custodian (to Vanguard from Edward Jones, for instance), do a direct transfer only. If you attempt to execute a regular rollover and you end up in possession of the funds, it will count as if you’d distributed the entire account.

Inherited IRA: Multiple Beneficiaries

If multiple beneficiaries inherit an IRA, they’re each treated as if they were non-spouse beneficiaries, and they each have to use the life expectancy of the oldest beneficiary when calculating RMDs. This is not a good thing, as it means less ability to “stretch” the IRA.

However, if the beneficiaries split the IRA into separate inherited IRAs by the end of the year following the year of the original owner’s death, then each beneficiary gets to treat his own inherited portion as if he were the sole beneficiary of an IRA of that size. This is a good thing, because it means that:

  • A spouse beneficiary will be treated as a spouse beneficiary rather than as a non-spouse beneficiary (thereby allowing for more distribution options), and
  • Each non-spouse beneficiary will get to use his or her own life expectancy for calculating RMDs.

Note: if the original owner dies in 2020 or later and at least one beneficiary is a “non-eligible beneficiary” (per the definition from the beginning in this article), then the whole account will have to be distributed within 10 years, unless the IRA agreement has a provision that immediately divides the IRA into separate IRAs for each beneficiary.

To split an inherited IRA into separate inherited IRAs:

  1. Create a separate account for each beneficiary, titled to include both the name of the deceased owner as well as the beneficiary.
  2. Use direct, trustee-to-trustee transfers to move the assets from the original IRA to each of the separate inherited IRA accounts.
  3. Change the SSN on each account to be that of the applicable beneficiary.

A Few Last Words

When you inherit an IRA, you absolutely must take the time to learn the applicable rules before you do anything. Don’t move the money at all until you understand what’s going on, because simple administrative mistakes can be very costly.

Also, should you elect to get help with the decision — a good idea, in my opinion — don’t assume that somebody knows the specifics of inherited IRA rules just because he or she is a financial advisor. In these circumstances, I’d suggest looking for someone with CPA or CFP certification.

**If a) the inherited IRA is a traditional IRA, b) you are older than the deceased IRA owner, and c) the deceased IRA owner had reached his “required beginning date” by the time he died, your RMD could actually be smaller than the amount calculated above, as you can calculate it based on what would be the deceased owner’s remaining life expectancy (from the “Single Life” table) using the owner’s age as of his birthday in the year of death (and reducing by one for each following year).

What Counts as Compensation (Earnings) for IRA Contributions?

I’ve received a few questions recently about what types of income count as “compensation” for IRA contribution purposes.

The definition of compensation is important because your IRA contributions for a given tax year are limited to the amount of your “compensation that is includible in your gross income” for the year. (If you are married, you and your spouse’s combined IRA contributions are limited to your combined such compensation.)

There are two key points here:

  1. The income in question must be something that is included in your gross income (e.g., foreign earned income that is excluded would not count), and
  2. It has to be income that counts as compensation.

So what counts as compensation?

Treasury Regulation 1.219-1(c) provides the following definition:

For purposes of this section, the term compensation means wages, salaries, professional fees, or other amounts derived from or received for personal service actually rendered (including, but not limited to, commissions paid salesmen, compensation for services on the basis of a percentage of profits, commissions on insurance premiums, tips, and bonuses) and includes earned income, as defined in section 401 (c) (2), but does not include amounts derived from or received as earnings or profits from property (including, but not limited to, interest and dividends) or amounts not includible in gross income.

In plain language, that means that the following count as compensation:

  • Wages/salary,
  • Commissions,
  • Net earnings from self-employment,
  • Scholarship or fellowship income if the income is reported in Box 1 of Form W-2 (i.e., reported as wages),
  • Taxable alimony and separate maintenance (i.e., for divorces that became finalized prior to 2019), and
  • Nontaxable combat pay.

And compensation does not include:

  • Interest or dividend income,
  • Other earnings or profits derived from property (e.g., rental income),
  • Social Security benefits,
  • Pension or annuity income,
  • Deferred compensation,
  • Income from a partnership for which you don’t provide services that are a material income-producing factor, and
  • Any income (other than combat pay) that isn’t included in your gross income.

For tax years 2020 and beyond, the SECURE Act made an additional change relating to fellowship/stipend income. Specifically, compensation will also include “any amount which is included in the individual’s gross income and paid to the individual to aid the individual in the pursuit of graduate or postdoctoral study.”

Compensation Reduced by Pre-Tax 401(k) Contributions

One noteworthy point here is that, when it comes to wages, it’s the amount that shows up in Box 1 of your Form W-2 that matters. And this amount in question is reduced by any pre-tax (“traditional”) 401(k) contributions that you make at work. Point being, if your earnings are low enough, pre-tax 401(k) contributions at work could reduce the amount you’re allowed to contribute to an IRA for the year. Roth 401(k) contributions do not, however, reduce the amount in Box 1. So Roth 401(k) contributions would not reduce the amount you can contribute to an IRA.

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