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This is why it is recommended to open a Roth and park $500 in there, for future use to be a qualifying account. That satisfies the "has had Roth" for that specific 5 year rule.
"although those Roths have been totally distributed in previous years"
So, this was the only open Roth? Well, the rule is in regards to first contribution to Roth account. Not to that Roth account.
"My understanding is that as long as she had any Roth prior to 2017"
It uses tax years. To meet the 5 year rule, funds removed in 2021 means the first contribution needed to be for tax year 2016, made as late as the filing of that tax return in 2017. Not "prior" to 2017, but made for Tax Year 2016, even if made in 2017.
Other 5 year rules relate to Contribution/Distribution, and to Conversion. The sequence for taking is Contributions, Conversions (which have their own 5 year rule) and Earnings. Conversions are based on the calendar year of the conversion for the 5 count.
Remember that the Code is used by the issuer. They don't know about the rest of her life or what else is going on or what she did with the funds. The earnings might be taxable, but at 63, there should not be a penalty.
You didn't mention why she did this:
"There are certain situations in which the 5-year rule for Roth IRAs can be ignored. You may take tax-free distributions from your Roth IRA at any time, at any age, and from any source (contributions, conversions or earnings) for any one of the following reasons:
- Making a down payment on your first house (withdrawal amount capped at $10,000)
- Paying for higher education for yourself, your spouse, your children or your grandchildren (withdrawal amount capped at $10,000)
- Paying for health insurance premiums
- If you become unemployed
- Paying for medical expenses that exceed 10% of your adjusted gross income (AGI)"
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