When I learned this (part of SECURE 2.0 I think), the earned income limitation applied.  I took a quick peek into 529(c)(3)(E) which led me to 408A(c)(2) which referenced 219 "without regard to (g)".  So it excludes the AGI phase out for Roth IRAs in 219(g) but I don't see where it excludes the earned income requirement in 219(b)(1)(B).  Was there an IRS notice or something that removed the earned income limitation?

Please share if you have something we can hang our hats on.  Otherwise I think I'm with Terry on this one.

Rick