By Kaye A. Thomas
Current as of February 11, 2018
Overview of how to undo a Roth IRA mistake by recharacterizing a contribution.
You might call it the “oops” rule. You can switch your IRA contribution from one type of IRA to another. Subject to some restrictions, you can go from Roth to traditional or from traditional to Roth. You can use this rule to recover from a failed conversion, or simply because you changed your mind about where your contribution should go. Now that’s a friendly rule!
The 2017 tax law partially repealed the recharacterization rule. Under prior law we could use this rule to undo a Roth conversion. We had until October 15 of the year following the conversion to reverse the transaction. This was particularly advantageous if investments lost value after a conversion: it was often possible to undo the conversion and then, after a waiting period, redo it at a smaller tax cost. The 2017 amendment does away with this planning opportunity. The recharacterization rules can still be used to make a retroactive change in the IRA to which you contributed, but it can no longer be used to undo a conversion.
The law’s effective date wasn’t entirely clear. Its literal language seemed to say we could no longer undo Roth conversions after 2017. The IRS adopted a favorable interpretation, however, taking the position that taxpayers who did Roth conversions in 2017 would have until October 15, 2018 to undo those conversions. Conversions occurring after 2017 cannot be undone, however.
About the only unfriendly thing about this rule is the seven-syllable word used to describe it. A better description, in just three syllables: it’s a do-over. This rule allows you to change something you did in the past, and treat it as if that’s the way you did it in the first place. You switch contribution money or conversion money from one type of IRA to another. If you follow all the rules, it’s as if you traveled back in time: you get to pretend the first choice never happened.
Here are some of the possible ways you could use this rule:
- Failed conversion. You converted a regular IRA to a Roth IRA in February. In November you realize the conversion included a required minimum distribution, which isn’t permitted. One way to fix that problem is with a recharacterization.
- Regular contribution to traditional IRA. You made a regular contribution to a traditional IRA and now you wish you had contributed that money to a Roth IRA instead. No problem! Substitute a Roth IRA for the traditional IRA as the recipient of that contribution.
- Regular contribution to a Roth IRA. The same thing works in the other direction. Maybe you found out your income was too high for the contribution to the Roth IRA, or you simply changed your mind about which type of IRA will work best for you. Whatever the reason, you can substitute a traditional IRA for the Roth IRA, and you’ll be treated as if the contribution originally went to the traditional IRA.
Here are additional ways the rule was used for pre-2018 conversions:
- Successful but unwanted conversion. Suppose your conversion didn’t fail, but it turned out to be a mistake? You found out later that you didn’t have enough money to pay the tax on the conversion. Or you discovered that this added income might prevent your child from receiving financial aid for college. Or you simply thought better of the whole idea. For pre-2018 conversions it was possible to move the money back to a traditional IRA, making the unwanted conversion disappear.
- Market losses after conversion. You made a good conversion and you still like the idea of a conversion — but you wish you hadn’t done it so soon. Your Roth IRA suffered market losses after the conversion, and that means you would report less tax if you were converting now. Here again, for pre-2018 conversions it was possible to use this rule to undo the conversion — and then do a new conversion after a required waiting period.
The scope of the recharacterization rule has been reduced to eliminate these possibilities for conversions taking place after 2017.
Bear in mind that recharacterization isn’t the only way to deal with a contribution you didn’t want to make. In some cases it makes more sense to move that contribution to another IRA, and in others it might make sense to withdraw the contribution under the excess contribution rules. But recharacterization is the only way you can rewrite the past, and make it as if your contribution originally went to a different IRA.