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There is Roth Conversion and there is recharacterization. Conversion is taxable to the extent the rollover does not represent a return of basis - this is the back-door IRA, at least for individuals who would not otherwise qualify because of their MAGI. Just about the only times when a conversion is not taxable is (1) the taxpayer has no other IRA, opened a brand new IRA, and rolled over everything (likely immediately) without any gain/loss or (2) the taxpayer rolled over all pre-tax dollars to a 401(k) and converted what's left in the IRA to a Roth.
Recharacterization from a traditional IRA to a Roth is not taxable but the taxpayer would have to be eligible for Roth contribution in the first place. This is not a back-door IRA.
Based on the above, which one fits your client's fact pattern?
There is Roth Conversion and there is recharacterization. Conversion is taxable to the extent the rollover does not represent a return of basis - this is the back-door IRA, at least for individuals who would not otherwise qualify because of their MAGI. Just about the only times when a conversion is not taxable is (1) the taxpayer has no other IRA, opened a brand new IRA, and rolled over everything (likely immediately) without any gain/loss or (2) the taxpayer rolled over all pre-tax dollars to a 401(k) and converted what's left in the IRA to a Roth.
Recharacterization from a traditional IRA to a Roth is not taxable but the taxpayer would have to be eligible for Roth contribution in the first place. This is not a back-door IRA.
Based on the above, which one fits your client's fact pattern?
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