if the brokerage calculated the attributable earnings over the investment performance of the entire account and then did an in-kind transfer of a number of shares having a total value on the date of the transfer equal to $6,000 plus the calculated gain (or loss), that would satisfy the requirements of CFR 1.408-11.
I beleive this is what the brokerage recharacterization tool was doing as described by their process I quoted in my previous reply.
In your case, the $100 gain would need to have been determined based on the overall investment performance in the Roth IRA, not just the performance of the shares that were moved in the in-kind transfer to the traditional IRA. Done as an in-kind transfer, the transfer would then have to consist of any shares from the Roth IRA having a value of $6,100 on the date of the transfer.
The in-kind transfer here meant I had to provde my brokerage an ordering of the shares in my Roth IRA to transfer over to the traditional IRA. The shares woiuld be transfer in-kind following the provided order until all of the calculated contribution plus or minus earnings and loss were covered. E.g. First transfer all of money market position, then transfer all of mutual fund position, lastly transfer stock position.
