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And perquisite #1 specifies a contribution. But a conversion is clearly treated distinctly from a contribution in other parts of Pub 590-B. And this requirement clearly states that you must make a Roth IRA contribution, so the nondeductible Traditional IRA contribution obviously doesn't start the clock.

Can you cite the specific place where conversions are cited as not being contributions in Pub 590-B? https://www.irs.gov/pub/irs-pdf/p590b.pdf

Here are some of the places that I found 'conversion' in 590-B:

Page 2 under "Reminders" Pub. 590-A covers contributions to traditional IRAs as well as Roth IRAs. This publication includes the rules for rollover and conversion contributions.

Page 7 under "Outstanding rollovers and recharacterizations" If a conversion contribution is contributed to a Roth IRA

Page 33 under "Ordering rules for distributions" There is a set order in which contributions (including conversion contributions and rollover contributions from qualified retirement plans)

Also page 33 under "Ordering rules for distributions" it refers to 'regular' contributions vs. 'conversion' contributions:
1. Regular contributions.
2. Conversion and rollover contributions, on a first-in, first-out basis (generally, total conversions and rollovers from the earliest year first).


So, I think your friends and co-workers are safe in not having to pay taxes on a qualified Roth IRA distribution from this year, as long as the account was funded with a conversion contribution in or before 2013.

AJ
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