Roth Conversion

§ 408A. Roth IRAs(a) General ruleExcept as provided in this section, a Roth IRA shall be treated for purposes of this title in the same manner as an individual retirement plan. (b) Roth IRAFor purposes of this title, the term “Roth IRA” means an individual retirement plan (as defined in section 7701(a)(37)) which is designated (in such manner as the Secretary may prescribe) at the time of establishment of the plan as a Roth IRA. Such designation shall be made in such manner as the Secretary may prescribe. (c) Treatment of contributions(1) No deduction allowedNo deduction shall be allowed under section 219 for a contribution to a Roth IRA. (2) Contribution limitThe aggregate amount of contributions for any taxable year to all Roth IRAs maintained for the benefit of an individual shall not exceed the excess (if any) of—(A) the maximum amount allowable as a deduction under section 219 with respect to such individual for such taxable year (computed without regard to subsection (g) of such section), over (B) the aggregate amount of contributions for such taxable year to all other individual retirement plans (other than Roth IRAs) maintained for the benefit of the individual. (3) Limits based on modified adjusted gross income(A) Dollar limitThe amount determined under paragraph (2) for any taxable year shall not exceed an amount equal to the amount determined under paragraph (2)(A) for such taxable year, reduced (but not below zero) by the amount which bears the same ratio to such amount as—(i) the excess of—(I) the taxpayer’s adjusted gross income for such taxable year, over (II) the applicable dollar amount, bears to (ii) $15,000 ($10,000 in the case of a joint return or a married individual filing a separate return). The rules of subparagraphs (B) and (C) of section 219(g)(2) shall apply to any reduction under this subparagraph. (B) DefinitionsFor purposes of this paragraph—(i) adjusted gross income shall be determined in the same manner as under section 219(g)(3), except that any amount included in gross income under subsection (d)(3) shall not be taken into account, and (ii) the applicable dollar amount is—(I) in the case of a taxpayer filing a joint return, $150,000, (II) in the case of any other taxpayer (other than a married individual filing a separate return), $95,000, and (III) in the case of a married individual filing a separate return, zero. (C) Marital statusSection 219(g)(4) shall apply for purposes of this paragraph. (D) Inflation adjustmentIn the case of any taxable year beginning in a calendar year after 2006, the dollar amounts in subclauses (I) and (II) of subparagraph (B)(ii) shall each be increased by an amount equal to—(i) such dollar amount, multiplied by (ii) the cost-of-living adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting “calendar year 2005” for “calendar year 2016” in subparagraph (A)(ii) thereof.