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Many doctors make a direct Roth IRA contribution, then later in the year realize their income is going to be higher than they thought and that direct contribution isn’t going to be allowed. Here’s an example from my email box:
Q. I am currently closing out my chief resident year and starting my Cardiology fellowship in July. I am doing my financial plan for next year. Last year I was fortunate to have the opportunity to moonlight and brought in an additional $60,000. Moreover, my wife received a raise and a bonus. Given this, we will be over the $206,000 Roth IRA contribution limit for 2020. I have been making the maximal contribution to our Roth IRAs for the past several years. I have not contributed to her Roth IRA for 2020 but have made the maximal contribution to my Roth IRA earlier this year before I realized that I would bring in this much extra money from moonlighting. I will be utilizing a Back Door Roth for her account so I can continue contributing there but I was curious if there is anything I can do retroactively for my account so I am not hit with any tax penalty.
A. It is really unfortunate since these doctors are trying to do the right thing. They are using a Roth IRA. They are funding it early in the year so there is more time for it to compound. They are busting their butt to get their income up. But then the IRS rules come down on them like a hammer. In fact, this circumstance is really common for people in the first year they do Backdoor Roth IRAs. A lot of people don’t realize that anybody CAN do a Backdoor Roth IRA. It’s just that high earners (along with people filing Married Filing Separately) HAVE to do a Backdoor Roth IRA. So if there is any doubt at all, do your Roth IRA through the Back Door, i.e indirectly. In fact, in 2010, the first year that the Backdoor Roth IRA was allowed, I did a Backdoor Roth IRA. I didn’t have to, though; my income turned out to be lower than I expected that year. If you have no idea what I’m talking about with a Backdoor Roth IRA, read this post first:
The Income Limit
The first thing to determine is whether this post even applies to you. If your income is below a certain amount, you can just contribute directly to a Roth IRA. That amount depends on several things. First, it is a MODIFIED Adjusted Gross Income (MAGI). That number is very similar to your Adjusted Gross Income (AGI). Remember how tax form 1040 works.
The first income line you come to is line 7b, your “Total Income”. When people think about income, this is generally what they think of. The third income line on the form is line 11b. This is your “Taxable Income”. This is what your tax bill is actually calculated from. It is basically your total income minus all of your deductions. In between those two, on line 8b, is another income, your “Adjusted Gross Income”. This is “the line” that people are talking about when they use the phrases “above the line deduction” and “below the line deduction.” If it comes out before your AGI is calculated, it is an above the line deduction. These are deductions such as self-employment tax, self-employed retirement plans, self-employed health insurance premiums, HSA contributions, student loan interest, alimony, tuition, and any IRA deductions. If it comes out after your AGI is calculated, it is a below the line deduction. These are EITHER your standard deduction OR your itemized deductions, like mortgage interest, state/local/property taxes, and charitable contributions. A MAGI is just a slight tweak to your AGI.
Here are the MAGI limits for 2020 for direct Roth IRA contributions. If your MAGI is below the first number, you can just contribute to a Roth IRA directly. If your MAGI is over the second number, you cannot contribute at all. If your MAGI is between the two numbers, you can make a partial direct contribution (most shouldn’t bother with this, just do it all through the Back Door).
- Married Filing Jointly: $196,000-$206,000
- Married Filing Separately (and lived with spouse for at least part of year): 0-$10,000
- Single or Head of Household: $124,000-$139,000
If you think you’ll be anywhere close to that first number, do yourself a favor and just do your Roth IRA contribution indirectly, i.e. through the Back Door (contribute to a traditional IRA and then convert that contribution to a Roth IRA). Since 2010, there has been no income limit on Roth conversions and there has never been an income limit on traditional IRA contributions, just your ability to deduct them.
So how does a MAGI differ from an AGI? It’s a very slight difference. Bear in mind that there are other MAGIs out there. We’re only talking about the one that affects Roth IRA contributions here. But to get your MAGI, you simply take your AGI, you subtract some income from it and you add back in some other income to it. The worksheet showing you how to do this is Worksheet 2-1 in Publication 590.
Basically, you subtract income from a Roth conversion and you add income from IRA deductions (not sure why you’d have this), student loan interest (if you are using this worksheet, you probably don’t have this), tuition deduction (you probably don’t have this), a couple of rare deductions for foreign income/deductions (you probably don’t have these), some savings bond interest you probably don’t have much of, and some employer-provided adoption benefits. As you can see, for most people your MAGI = your AGI since all of these deductions are pretty rare for the folks worried about this limit for direct Roth IRA contributions. So focus on your AGI. That means if you contributed directly to a Roth IRA but late in the year realized you probably should not have, one easy fix is to get your AGI below that limit by contributing to an HSA or a self-employed retirement plan like an individual 401(k) or SEP-IRA. Note that giving a bunch of money to charity is NOT a solution to this problem because that is a below-the-line deduction.
How to Do an IRA Recharacterization
If you can’t get your MAGI low enough, you will have to do an IRA Recharacterization. With a recharacterization, as far as the IRS is concerned it is as though you never made the Roth IRA contribution at all, but made a traditional IRA contribution instead. You don’t report a recharacterization separately, you just report a traditional IRA contribution. Keep in mind as you read on the internet about recharacterizations that there used to be two types of them—a recharacterization of a Roth IRA CONTRIBUTION and a recharacterization of a Roth IRA CONVERSION. The second type was outlawed in 2018, but the first one, the one we’re talking about today, is still perfectly legal. If you decide you want to undo a Roth conversion these days, you’re simply out of luck. Here is how you do a recharacterization of a Roth IRA contribution:
You tell Vanguard (or wherever your IRAs are) to recharacterize the Roth IRA contribution to a Traditional IRA contribution.
Yup. That’s it. They take care of the rest. I mean, you can read all about all of the rules in Publication 590 Chapter 1 if you want, but that’s basically what they say. Don’t believe me? Fine. Here’s the IRS instructions:
How Do You Recharacterize a Contribution?
To recharacterize a contribution, you must notify both the trustee of the first IRA (the one to which the contribution was actually made) and the trustee of the second IRA (the one to which the contribution is being moved) that you have elected to treat the contribution as having been made to the second IRA rather than the first. You must make the notifications by the date of the transfer. Only one notification is required if both IRAs are maintained by the same trustee. The notification(s) must include all of the following information:
- The type and amount of the contribution to the first IRA that is to be recharacterized.
- The date on which the contribution was made to the first IRA and the year for which it was made.
- A direction to the trustee of the first IRA to transfer in a trustee-to-trustee transfer the amount of the contribution and any net income (or loss) allocable to the contribution to the trustee of the second IRA.
- The name of the trustee of the first IRA and the name of the trustee of the second IRA.
- Any additional information needed to make the transfer.
In most cases, the net income you must transfer is determined by your IRA trustee or custodian.
See what I mean? It’s just a phone call. Any earnings that the account had in between the contribution and the recharacterization just go over with the contribution. No big deal.
You have until your tax filing date to do this. Most of the time, that’s April 15th of the next year. However, the IRS is even more lenient than that. You actually can do this for an extra six months after your tax filing date, but you will have to refile your return.
Where Do You Report a Recharacterization?
If you hire somebody else to prepare your taxes, you can skip this section. If you do it yourself, you’ll need to make sure you report this correctly. According to Pub 590, you report it on our old friend Form 8606.
Pub 590 says this:
Actually, that’s really misleading. If you read Form 8606, you will see that the only time it ever mentions a recharacterization is to tell you NOT to put it on the form.
So what is Pub 590 talking about? They’re talking about this section in the 8606 instructions:
Treat any recharacterized IRA contribution as though the amount of the contribution was originally contributed to the second IRA, not the first IRA. For the recharacterization, you must transfer the amount of the original contribution plus any related earnings or less any related loss. In most cases, your IRA trustee or custodian figures the amount of the related earnings you must transfer. If you need to figure the related earnings, see How Do You Recharacterize a Contribution? in chapter 1 of Pub. 590-A. Treat any earnings or loss that occurred in the first IRA as having occurred in the second IRA. You can’t deduct any loss that occurred while the funds were in the first IRA….Report the nondeductible traditional IRA portion of the recharacterized contribution, if any, on Form 8606, Part I. Don’t report the Roth IRA contribution (whether or not you recharacterized all or part of it) on Form 8606. Attach a statement to your return explaining the recharacterization. If the recharacterization occurred in 2019, include the amount transferred from the Roth IRA on Form 1040 or 1040-SR, line 4a; or Form 1040-NR, line 16a. If the recharacterization occurred in 2020, report the amount transferred only in the attached statement, and not on your 2019 or 2020 tax return.
The bottom line is that you just report this recharacterized contribution on Form 8606 as if it were the regular old non-deductible traditional IRA contribution that you should have made in the first place. You also need to include a statement. What should your statement look like? I would write something like this:
To whom it may concern:
I made a 2020 Roth IRA contribution of $6,000 on March 13th, 2020, because I didn’t know about the whole MAGI limit thing when I made the contribution. After becoming smarter, I recharacterized $6,137.14 (original contribution plus earnings) to a traditional IRA on November 4th, 2020, Thank you for helping our country fund its government. You’re the best.
Hugs and kisses from your favorite taxpayer,
Seriously. It doesn’t say what has to be on the statement, just that there is one “explaining the recharacterization”. You don’t even have to tell them why you did the recharacterization. If you had a loss in the account between contribution and recharacterization, no big deal. It’s still as though you made a $6,000 contribution to a traditional IRA and THEN it lost money. If you were able to deduct the contribution (you probably can’t) you would get a $6,000 deduction. The IRA provider may also send you a Form 5498 (which has the recharacterized amount on line 4), but you don’t actually do anything with it when you file your taxes. It’s just an informational return.
Reconverting the IRA
Now here is where it gets interesting. You’ve now fixed your mistake in the eyes of the IRS, going from an illegal Roth IRA contribution to a legal traditional IRA contribution (that is probably not deductible for you). But you really aren’t done with what you meant to do, which is put money into a Roth IRA. You now need to do a Roth conversion. You do it just like you normally would as if you had contributed originally to the traditional IRA. You can do it the very next day if you like. You can probably even do it the same day, just make sure there is a paper trail showing the money was actually in the traditional IRA at some point. There used to be a waiting period after a recharacterization before you could do a Roth conversion on that money, but that waiting period only ever applied to the recharacterization of a Roth CONVERSION (which is no longer allowed starting in 2018) NOT the recharacterization of a Roth CONTRIBUTION. So there is no waiting period. Just
reconvert convert it and go on your merry way.
I hope this information helps you fix your mistake. Just do your Roth IRA contributions through the Back Door going forward and you won’t have this problem again. If you need to fix other Back Door Roth IRA mistakes, check out this post.
What do you think? Have you had to do a recharacterization of a Roth contribution? What happened? Comment below!