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New Member
posted Jun 4, 2019 10:11:21 PM

Can I recharacterize my ROTH 401K contributions from 2017 into my former ER plan by rolling it out to a Roth IRA and recharacterizing that Roth IRA to a traditional IRA?

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6 Replies
Level 15
Jun 4, 2019 10:11:23 PM

You can only recharactorize a Roth conversion from a Traditional IRA back to a Traditional IRA.   (Rechactorized means putting it back to where it came from).

You cannot convert a Roth IRA to a Traditional IRA which is this would be since the Roth is not a conversion  but a rollover from an existing 401(k) Roth.   Since a Roth is after-tax money, converting it to before-tax money cannot be done and is not allowed.

(Note that after Dec 31, 2017 Roth recharacterizations can no longer be done under the new tax law).

New Member
Jun 4, 2019 10:11:24 PM

I'm looking at the following FAQ from the IRS ...

<a rel="nofollow" target="_blank" href="https://www.irs.gov/retirement-plans/retirement-plans-faqs-regarding-iras-recharacterization-of-roth-rollovers-and-conversions">https://www.irs.gov/retirement-plans/retirement-plans-faqs-regarding-iras-recharacterization-of-roth-rollovers-and-conversions</a>

Q2 seems to indicate I can do what I asked.  

Also, I thought the new tax law only changed recharacterizations for 2018 contributions, and that they couldn't change 2017 tax law that gave individuals until October 15th of the following year to make the determination for the prior year.

Level 15
Jun 4, 2019 10:11:25 PM

I believe that is referring to a 401(k) (or other before tax) employer plan that was rolled in to a Roth IRA that would make it a taxable event on the the tax return for the year that it took place.   It can then be recharacterized from the new after-tax Roth back to a before-tax Traditional IRA which would cancel the taxable rollover to the Roth.    A non-taxable rollover form a preexisting 401(k) Roth to a Roth IRA cannot be converted to a Traditional IRA.   A recharactorization can only cancel a tax that you would have paid, it cannot return tax that was paid when the 401(k) contributions were made.   It would appear that that FAQ does not make that clear. [ @dmentz - check me on this please.]

HR1 (new tax law) SEC. 13611. Repeal of special rule permitting recharacterization of Roth conversions.
(b) Effective date.—The amendments made by this section shall apply to taxable years beginning after December 31, 2017.

Some think that would not apply to rollover/conversions made in 2017 and recharactorized in 2018 and other think that since the change will apply to any Roth recharactorization done in 2018.    It depends how the IRS will apply the new law, but I would not count on it being allowed at all in 2018.

<a rel="nofollow" target="_blank" href="https://www.cnbc.com/2017/12/19/roth-ira-conversions-cant-be-undone-under-gop-tax-reform.html">https://www.cnbc.com/2017/12/19/roth-ira-conversions-cant-be-undone-under-gop-tax-reform.html</a>
<a rel="nofollow" target="_blank" href="http://fox2now.com/2017/12/06/new-tax-bill-and-changes-to-roth-ira-accounts/">http://fox2now.com/2017/12/06/new-tax-bill-and-changes-to-roth-ira-accounts/</a>

New Member
Jun 4, 2019 10:11:28 PM

Thank you macuser - very helpful.

Level 15
Jun 4, 2019 10:11:29 PM

No.  Once you contribute to a Roth 401(k), either as an original contribution or by In-plan Roth Rollover, the money and the earnings on that money are forever Roth.  Recharacterization of money in a Roth 401(k) is not permitted.  Rolling Roth 401(k)  money over to a Roth IRA doesn't change anything.

Recharacterizations are only permitted on original contributions to a traditional IRA, original contributions to a Roth IRA, Roth conversions from a traditional IRA, or rollovers from a traditional 401(k) or similar traditional qualified retirement account to a Roth IRA.  The last two are not permitted for tax years after 2017.

Level 15
Jun 4, 2019 10:11:31 PM

I added some details to my answer.