RMD to ROTH CONVERSION

[dyne]

It has been argued that for the year 2009 ONLY since no rmd is required, any amount
distributed from an IRA can be put into a ROTH CONVERSION. In researching it is
clear that any amount distributed as RMD can NOT be put into a ROTH CONVERSION.
But everything I have found keeps saying required minimum distributions may not be
put into a Roth Conversion. But for 2009 there technically is NO rmd required. Would
that then allow a voluntary distribution equal to a rmd to be allowed to be put into a Roth
Conversion? I think NOT but cannot find clear authority. Comments?

[taxmom34]

just a thought popped in my head. would it be a different issue if it wasn't called RMD? what if it was just treated as a regular distribution ?

[dyne]

My understanding is that if it is a regular distribution and is in EXCESS of the RMD, then
it can be rolled over or put into a ROTH CONVERSION as long as the taxpayer has no
basis or cost in it. Of course the amount put into a ROTH CONVERSION is taxable.

[dyne]

Does Part II of IRS Notice 2009-82 prohibit amounts distributed during 2009 which would
normally be thought of as RMD from being rolled over or put into a ROTH CONVERSION?
I am not at all sure but that is going to be my position unless someone else finds authority
for a different conclusion.