In IRS notice 2020-68 the IRS provides additional guidance. I am basing my example for when a person solely has IHSS income. In order to make a Roth contribution one must have taxable income. IHSS is the same as difficulty of care income and is not taxed on the federal level. Therefore this income is ineligable for a ROTH contribution because the income has never been federally taxed. A ROTH contribution must be federally taxed. Therefore, IHSS income is solely eligible for a non-deductible Traditional IRA contribution so that when distributions begin in retirement the contribution and any proceeds become federally taxable.
