Retirement tax questions

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@timw657 wrote:

Thanks for your reply. I am interested in paying the taxes due for the conversion over 3 years, which I think is allowed. Some tax advisors say this violated the spirit of the law, and the IRS will likely disallow it in the future, with penalties for those who took a CRD and converted it to a Roth ira. I'd like some assurance that it really is legal. Thats all. It was a 100,000 conversion, so paying taxes on a 33,333 conversion each of 3 years is my plan.

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I do not believe that is permitted under the CARES act that allows returning the money to the plan that it came from or a like plan as a rollover.  A Roth conversion would not qualify,

Section §2202(a)(3) or the CARES act says:

(3) Amount distributed may be repaid.--
                    (A) <<NOTE: Time period.>>  In general.--Any 
                individual who receives a coronavirus-related 
                distribution may, at any time during the 3-year period 
                beginning on the day after the date on which such 
                distribution was received, make 1 or more contributions 
                in an aggregate amount not to exceed the amount of such 
                distribution to an eligible retirement plan of which 
                such individual is a beneficiary and to which a rollover 
                contribution of such distribution could be made under 
                section 402(c), 403(a)(4), 403(b)(8), 408(d)(3), or 
                457(e)(16), of the Internal Revenue Code of 1986, as the 
                case may be.

It plainly states a "rollover contribution" and a conversion is not a rollover and none of the quoted sections pertain to a Roth conversion.