Until now, the option of contributing to a Roth IRA was
limited to those individuals with modified adjusted gross incomes below roughly
$176,000 (for married taxpayers filing jointly) or $120,000 (for single
taxpayers or those filing as head of household).[1] While these limits remain in place for direct
contributions to Roth IRAs, 2010 has brought a new opportunity for taxpayers at
all income levels to establish Roth IRAs by converting traditional IRAs into
Roth IRAs. This offers an important
possibility for tax savings, and in some cases estate planning, for many
individuals.
This article provides an overview of the basic rules and tax
implications of Roth IRA conversions, as well as the key considerations for
individuals considering this option. Particular
attention is devoted to the potential tax savings and estate planning
opportunities that this development presents for many individuals with relatively
high net worth. As set forth below, this
article concludes that the potential extended tax-free growth offered by a Roth
IRA conversion is generally most advantageous for individuals who (i) are able
to pay the income tax resulting from the conversion with non-IRA assets, (ii) are
likely to be able delay or avoid lifetime withdrawals from the IRA, (iii) are
relatively young, and/or (iv) do not expect to be in a significantly lower tax
bracket when funds are withdrawn.
Tax Treatment and Advantages of Roth IRAs
Before exploring the mechanics and tax implications of a
Roth conversion, it is important to understand the basic tax treatment of Roth
IRAs.
Unlike some contributions to traditional IRAs, direct
contributions to Roth IRAs are not tax deductible. Accordingly, where contributions to a
traditional IRA were tax deductible and any portion of the IRA is subsequently
converted to a Roth IRA, the converted amount is treated as taxable income.[2] (The timing of such income inclusion is discussed
in greater detail below.) The advantages
of a Roth IRA, however, in some cases far outweigh the drawback of this upfront
tax.
First and most important, qualified withdrawals from a Roth
IRA are free of income tax. This means
that unlike a traditional IRA, in which gains are taxed as ordinary income as
they are distributed, all gains on a Roth IRA are tax-free as long as only
qualified distributions are made from the account. For a Roth IRA withdrawal to be excluded from
taxable income, (i) the account owner must be at least age 59½ and (ii) at
least five years must have elapsed since the owner's first contribution to any Roth IRA. (These rules apply to lifetime withdrawals by
the owner; as discussed below, different rules apply where an IRA is
distributed to beneficiaries upon the owner's death. Special exceptions also apply under certain
circumstances such as the owner being permanently disabled.) In addition, traditional IRAs converted to
Roth IRAs are subject to a five-year waiting period that is calculated separately
based on the conversion date of the applicable IRA; withdrawals made before
this five-year waiting period are subject to a 10% penalty tax. Thus, assuming that these basic requirements
are met, Roth IRAs offer the benefit of entirely tax-free growth following the initial
contribution or conversion.
Second, Roth IRAs offer more flexibility than traditional
IRAs with respect to required minimum distributions or "RMDs." Under the rules of a traditional IRA, the owner
must begin annually withdrawing 4-5% of the account balance upon reaching age
70½ (increasing to over 6% per year at age 81) in order to avoid substantial
tax penalties. Thus, even where an
individual does not currently need the assets in his or her traditional IRA, he
or she is essentially forced to make annual withdrawals from it - thereby
losing the benefit of holding the assets in the IRA - after reaching age
70½. The holder of a Roth IRA, on the
other hand, is not required to make any withdrawals from the account during his
or her lifetime. Thus, a Roth IRA's
tax-free compounding may continue throughout the owner's lifetime, or at least
until he or she needs the assets.
Roth IRAs, like traditional IRAs, are subject to RMDs if the
owner dies without exhausting the funds, leaving the Roth IRA to
beneficiaries. (An exception is made
where the account beneficiary is the owner's spouse, as he or she may treat the
account as his or her own and thereby delay withdrawals.) Generally, the funds in a Roth IRA are
required to be distributed by the end of the fifth year following the owner's
death. However, this time period may be
"stretched" over a period not to exceed the beneficiary's expected lifetime if
distributions commence the year after the owner's death and the Roth IRA is
payable to one or more "designated beneficiaries" (i.e., individuals and/or
trusts that meet certain qualifications[3]). Therefore, especially where a Roth IRA
is left to a fairly young beneficiary, its tax-free compound growth may last for
many years.
Finally, in the context of Roth IRA conversions, individuals
with sufficient outside assets may pay the tax attributable to the conversion
with non-IRA assets. This in effect
enables one to make a substantial additional contribution to the Roth IRA, as
the initial amount that is allowed to grow tax-free is never reduced by any
income tax. As discussed later, the benefit
of a Roth IRA conversion increases greatly where an individual is able to take
advantage of this option.
Conversion
The mechanics of converting a
traditional IRA to a Roth IRA are generally fairly straightforward; an
individual normally simply contacts the administrator of his or her existing
IRA and arranges to have some amount converted to a Roth IRA with the same
administrator. The determinations of
when and in what manner to make a conversion, however, are somewhat more
complex.
As noted above, an amount converted from a traditional IRA
to a Roth IRA is normally included in the account owner's taxable income in the
year of conversion. A special exception applies
to conversions completed in 2010; although the owner may elect normal treatment
(i.e., inclusion of the converted amount in 2010 income), inclusion of the
converted amount may instead be delayed, with half of the amount included in
taxable income for 2011 and half in 2012.
While Roth IRA conversions may be made in later years (barring, of
course, a change in the law), this special treatment applies only to those
completed in 2010.
Normally, delaying the recognition of taxable income
provides at least a modest benefit, as it delays the payment of tax. In this case, however, the advantage of
delayed tax must be weighed against several factors favoring earlier inclusion. First, tax rates are scheduled to increase
beginning in 2011; the tax rate for the highest federal tax bracket, for
example, is scheduled to increase from the current 35% to 39.6%. Second, some experts predict that many assets
will appreciate fairly substantially in the near future as the market continues
to recover. Third, the delay in
conversion also delays the primary benefit of the Roth IRA: tax-free compound
growth. Therefore, some individuals may
wish to convert IRAs this year and treat the converted amount as 2010 taxable
income rather than delaying its recognition until 2011 and 2012. Finally, one should consider the impact of a
conversion on his or her tax bracket.
Some might find that splitting the converted amount between 2011 and
2012 prevents them from being pushed into a higher tax bracket for both years,
while others might benefit more from having the converted amount included in
only one year (thereby limiting the tax-bracket increase to one taxable year);
this of course depends on one's other expected income and the amount converted.
In addition to the timing of a conversion and (in the case
of 2010 conversions) the timing of income inclusion, an individual must
determine the amount(s) to convert and how many Roth IRAs to establish. Any portion of an individual's traditional
IRA(s) may be converted to one or more Roth IRAs. One interesting - and potentially
advantageous, as discussed below - dimension to Roth IRA conversions is that an
individual may establish multiple Roth IRAs (even where only one traditional
IRA is being converted) and direct different kinds of assets to each account.
Recharacterization
Another unique feature of
Roth IRA conversions is that they typically may be undone (or
"recharacterized") the following year. Recharacterizations
may not be made in the year of conversion, but generally may be made anytime
until October 15 of the year after the conversion (i.e., most individuals'
extended income tax deadline for the year of conversion). This gives individuals some flexibility to
rethink a conversion, and is particularly useful if the value of a converted
amount decreases substantially. In that
case, an individual might elect to recharacterize the amount and try a
conversion again later in order to include the reduced amount in taxable
income. A recharacterization entails
some risk that the recharacterized amount will increase prior to the next
conversion, particularly because the new conversion may not be completed until
the later of (i) the year after the recharacterization and (ii) 30 days after
the recharacterization. Moreover, an
individual must take into account any expected increases in the applicable tax
rate as discussed previously. However,
where an asset depreciates considerably after a conversion, a
recharacterization can be advantageous.
These recharacterization rules are structured such that
individuals can attempt to maximize the benefit (and minimize the drawbacks) of
a Roth IRA conversion. Because of the
timing restrictions set forth above, it may be beneficial to complete a conversion
early in a taxable year in order to have almost two years to decide whether to
recharacterize the amount. In addition,
most individuals should elect to hold off on a recharacterization until late in
the applicable year in order to best gauge the performance of the converted
amount(s), as a new conversion will not be allowed in any event until the
following year.
Finally, a key attractive element of the conversion and
recharacterization rules is that the owner may pick and choose which Roth IRA
account(s) to recharacterize. As noted
above, an individual may convert a single traditional IRA into a number of Roth
IRAs, each with a specific type of investment, thereby "unpacking" a
diversified traditional IRA into multiple Roth IRAs with different kinds of
holdings. As most investors are aware,
the market does not always perform uniformly; some types of assets may do very
well while others depreciate substantially over the same period. Thus, as one analysis points out, "You can
cherry-pick the losing account to get a lower tax cost via recharacterization,
while leaving the winners to keep growing and eventually pay out tax‑free
profits."[4]
Weighing a Potential Conversion:
Primary Considerations
A number of resources provide comparative analysis of the potential
outcome of a Roth IRA conversion (as opposed to maintaining a traditional
IRA) based on varying factors such as timing of withdrawals, age at conversion,
and changes in tax rates. Bernstein
Global Wealth Management's publication entitled Roth to Riches? Determining
Whether a Roth Conversion Makes Sense,[5]
for example, provides useful comparative analyses based on varying hypothetical
circumstances. In addition, online tools
such as Vanguard's "Roth IRA conversion calculator"[6]
provide alternate projections based on one's personal information. This sort of financial modeling and
customized analysis is beyond the scope of this article. However, a number of trends emerge from these
analyses that highlight the following considerations as especially critical
when determining whether (or to what extent) to convert a traditional IRA to a
Roth IRA.
Although other considerations
may come into play, as discussed in the next section, four primary factors
generally determine the advisability of a Roth IRA conversion, as well as the
extent to which a conversion provides tax savings and estate planning
opportunities.
1. Ability to pay the tax attributable to
a Roth IRA conversion from non-IRA assets.
One of the most significant advantages of a Roth conversion,
as noted above, is the opportunity it affords to effectively make an additional
contribution to the IRA by paying the conversion tax with outside assets. A primary benefit of a traditional IRA is
that it allows long-term growth of pre-tax assets, whereas a Roth IRA normally
only includes contributions of after-tax assets (but allows all further growth
to go untaxed). By paying the conversion
tax with outside assets, an individual is able to take advantage of both of these
benefits: the full amount of the pre-tax traditional IRA contributions remains
in the account, while all further growth goes untaxed due to the Roth
conversion. Although financial analysis
shows that a Roth conversion can still provide tax savings for some traditional
IRA holders who pay the conversion tax with IRA assets, the benefit is reduced
compared with the substantial tax savings possible when the conversion tax is
paid with outside assets and the full IRA account is left intact to grow
tax-free.[7]
2. Age.
One need not be 25 to benefit from a Roth conversion. However, the longer the period of time
between the conversion and the commencement of withdrawals, the greater the
benefit of the Roth's tax‑free growth.
For individuals who do not expect to make lifetime withdrawals from an
IRA (as discussed later), age at conversion is less of a deciding factor
because the account will likely have time to grow during the lives of the
beneficiaries. Individuals who expect to
withdraw at least some of the account funds during their lifetimes, however,
should consider their age at the time of conversion. Generally, the analyses indicate that an IRA
owner who is 55 or younger at the time of a Roth conversion is more likely to
benefit from the conversion regardless of other factors such as moderate changes
in tax rates or, to some extent, the ability to pay the conversion tax with
non-IRA assets. This is not to say that
a 65-year-old who anticipates making lifetime withdrawals should rule out a
Roth conversion (particularly if such withdrawals may be delayed at least 5 or
10 years), but simply that he or she must take greater account of the other
factors determining the advisability of a conversion.
3. Comparative
tax rates.
Whether it is more favorable
to pay tax now (upon a Roth conversion) or later (upon withdrawal from a
traditional IRA) depends in part on one's comparative tax rates now and in the
future. A traditional assumption is that
one's tax rate will decrease upon retirement due to a reduced stream of income,
which would weigh in favor of maintaining a traditional IRA in order to pay tax
on withdrawals at a future lower tax rate rather than paying tax on a converted
amount at one's current tax rate.
However, this may not be the case for wealthy individuals or those who
continue to work beyond a traditional retirement age (particularly beyond 70½,
the age at which traditional IRAs require minimum annual distributions to
commence). Individuals who expect to
retire in another state should also consider whether this will likely increase
or reduce their effective tax rate; Florida, for example, currently has no
income tax, while California currently has very high income tax rates for higher-income
individuals. Thus, one's personal
circumstances can have a significant impact on this factor.
In addition, it is very possible that tax rates will
increase in the future due to both scheduled near-term rate increases and
long-term revenue requirements. This
could at least partially offset any tax-rate reduction from decreased income in
retirement. Because anticipated changes
in the tax rates are naturally speculative, some advisors suggest converting
only a portion of one's traditional IRA(s) to Roth IRAs in order to diversify
one's retirement portfolio from a tax perspective.[8] In this respect, the Roth IRA protects
against tax rate increases, while the traditional IRA takes advantage of any
decreases in tax rates at retirement.
It is important to understand in this context, however, that
even if one's tax rates decrease upon retirement, the reduction must be quite considerable
in many cases to outweigh the benefits of a Roth IRA conversion if one is able
to pay the conversion tax with outside assets; this is particularly pronounced
if the conversion is done at least ten years before withdrawals begin, either
because the IRA owner converts the IRA well before retirement age or because he
or she is able to delay making withdrawals from the account after retiring. Depending how long the funds are left
untouched, a ten or even twenty percentage-point drop in one's tax rate may be
outweighed by the benefits of the converted Roth's tax-free growth.[9] On the other hand, a 65-year-old who expects
to begin making moderate withdrawals in the near future is likely to fare
better maintaining a traditional IRA (rather than converting it to a Roth) if
his or her tax rates will drop even fairly modestly.[10]
Finally, for those planning to use an IRA as a vehicle for
transmitting wealth to the next generation, it is relevant to consider the
future tax rates of the IRA's intended beneficiaries. Even if the beneficiaries are expected to be
in lower tax brackets than that of the IRA owner, however, this must be weighed
against the benefit of a Roth IRA's long-term growth possibilities, as
discussed below.
4. Ability to delay
withdrawals.
Finally, the ability to delay
withdrawals from an IRA weighs in favor of a Roth conversion-and for some
individuals offers an excellent estate planning opportunity. As noted previously, Roth IRAs have no
required minimum distributions during the account owner's lifetime. For those who must utilize some IRA funds
during their lifetimes, the ability to delay the use of these funds - for
example until age 70 or 75 - frequently offsets the drawback of making a
conversion at a relatively late age such as 65.
The longer one can delay such withdrawals, the greater the benefit of
the Roth's tax-free compound growth.
For those who can make modest lifetime withdrawals - or
better yet, none at all - a Roth IRA can be a valuable tool for making tax-efficient
transfers of wealth to one's heirs.
Although a Roth IRA (like a traditional IRA) is included in one's estate
for estate tax purposes, its benefits of income-tax-free growth can extend well
beyond one's lifetime. As noted above,
as long as a Roth IRA's beneficiaries are individuals or qualified trusts
established for the benefit of individuals, the account generally qualifies for
"stretch" treatment. This means that
required minimum distributions may be spread across a beneficiary's expected lifetime,
giving the account assets far more time to appreciate free of income tax.
Because of this opportunity to continue tax-free growth, a
Roth IRA can provide a far greater financial benefit to beneficiaries than an
inherited traditional IRA or cash gift. As
Bernstein's analysis demonstrates, a Roth IRA conversion could still be highly
beneficial even for a beneficiary who is age 55 at the time of the account
owner's death, and whose tax rate is as much as twenty percentage points below
the account owner's at the time of conversion, because required minimum
distributions would be spread across a 30-year period following the account
owner's death. Some analysts even assert
that the magnitude of this benefit is substantial enough to significantly
outweigh any imposition of the generation-skipping transfer ("GST") tax (which
is applicable when an individual exceeds his or her $1,000,000 GST tax
exemption), thereby making a Roth IRA a potentially attractive asset to leave
to grandchildren.[11]
Of course the benefits of delayed required minimum distributions
are only applicable to the extent that an account owner and his or her
beneficiaries are able and willing to refrain from making account
withdrawals. In this respect, some
individuals may find it appealing to establish a trust to hold the Roth IRA in
order to prevent beneficiaries from making unnecessarily early
withdrawals. It is critical, however,
that such a trust be properly drafted and administered to qualify as a
"designated person," as discussed previously, in order to avoid the standard
five-year required distribution period following the account owner's death. (Alternatively, an account owner may
establish a "trusteed IRA" for similar purposes.[12]) Finally, it is also essential that an
individual refrain from naming his or her estate as the Roth IRA account
beneficiary, as an estate does not constitute a designated person and this
would trigger the five-year distribution period, thereby preventing the benefit
of otherwise delayed distributions.
Additional Considerations
While the above considerations constitute the primary
determining factors for most people, some of the following considerations may
also be applicable to an individual considering a Roth IRA conversion.
1. Income tax deductions
to offset conversion income.
A Roth conversion may be
especially beneficial for individuals with deductions available to at least
partially offset the additional taxable income generated by the
conversion. In this context, it is
important to note that conversion income may be offset by ordinary income
deductions such as charitable deductions (including "carryforwards" from prior
years) and business net operating losses, but not by capital losses.
Individuals who regularly have ordinary income tax deductions
may wish to accelerate them into the year of conversion to the extent possible,
such as by incurring business expenses in advance or by making a larger
charitable gift in the year of conversion.
Depending on the size of the charitable gift, some donors might wish to
make this one-time contribution to a donor-advised fund, which could then make
smaller charitable gifts over time based on the donor's ongoing requests.[13]
The timing of available deductions also could influence the year
in which an individual elects to make a conversion and to include the amount in
taxable income. For example, an
individual who has a substantial carryforward deduction that will expire in
2010 might wish to complete a conversion in 2010 and to include the converted amount
in 2010 taxable income.
2. Estate taxes.
As many are aware, estate taxes have been temporarily
eliminated in 2010 barring further Congressional action. However, they are scheduled to return in 2011
and most likely will remain part of the tax landscape, whether with the
scheduled $1 million exemption or some other amount such as the $3.5 million
per person exemption that was applicable in 2009. Thus, the potential estate tax impact of a
Roth IRA conversion is worth considering for individuals who are likely to
exceed the exemption amount.
Where an IRA is used as an estate planning vehicle, some analysts
assert that a Roth IRA conversion provides estate tax savings. This is because paying income tax on the
converted amount reduces the owner's taxable estate and saves beneficiaries
from paying income tax later (as opposed to traditional IRAs that require
beneficiaries to pay income tax on gains as distributions are made). This benefit is partially offset by the fact
that income tax credits are generally available to beneficiaries of a
traditional IRA based on the amount of any estate tax paid with respect to the
IRA. However, these credits are phased
out for higher-income beneficiaries, and certainly could be eliminated in the
future. Moreover, such credits apply
only to federal estate taxes; similar credits would not necessarily be
available for any state estate taxes paid on the IRA, so this could weigh in
favor of a Roth conversion.
On the other hand, the benefit of tax-free growth with no
required minimum distributions during the account owner's lifetime increases
the account's size and therefore the owner's taxable estate, presumably
increasing the owner's total estate tax liability. Therefore, it is fairly unlikely that a Roth
conversion would afford significant estate tax savings. It is important, however, for any estate
taxes to be paid with non-IRA assets to the extent possible in order to protect
the amount that may continue to grow tax-free over beneficiaries' expected
lifetimes.
3. IRAs as charitable gifts.
Traditional IRAs are typically considered excellent
candidates for charitable bequests because this avoids any income tax being
paid on the account; tax-deductible contributions are made upfront, and (unlike
other kinds of beneficiaries) the tax-exempt charity is not required to pay
income tax on the distributions. Where
beneficiaries are likely to exhaust an IRA account soon after the owner's
death, this still holds true; it is likely best in that case to maintain a
traditional IRA to leave to charity, and make cash bequests to
beneficiaries. However, where
beneficiaries are likely to leave an inherited IRA largely intact (even over a
period of ten or more years, if not over their expected lifetimes) - thereby taking
advantage of a Roth IRA's long-term tax-free growth - the analysis indicates
that it may be best to make a Roth conversion, leaving the Roth IRA to one's
heirs and a cash gift equal to the amount that would have been in the
traditional IRA to charity.[14]
4. Risk tolerance.
Many of the issues involved in the determination of whether
to make a Roth IRA conversion - such changes in tax rates, needs in retirement
and life expectancy - involve a fair amount of uncertainty. Most of these factors involve some amount of
risk in either direction; one's tax rates could skyrocket, for example, making
a traditional IRA far less advantageous than a Roth, or could plummet,
potentially making the traditional IRA more favorable. However, one issue to consider that would
drastically alter the analysis herein - potentially making a Roth conversion
quite detrimental - is the possibility that the tax treatment of existing Roth
IRAs could change. It does not appear
that any such change is on the horizon, and even if tax treatment of Roth IRAs
generally were to change, existing accounts could be subject to some sort of
"grandfathering" policy that would preserve the tax-free status of future
withdrawals from those accounts. However,
there is inherently some risk in electing to pay tax now with the expectation
that future distributions will be tax-free in accordance with today's tax
rules, as the current benefits of Roth IRAs could be subverted by future
legislation. Individuals who consider
this a significant risk may choose not to make any Roth IRA conversions,
or at least to maintain a portion of their existing accounts as traditional
IRAs.
Conclusion
As described herein, Roth IRA conversions offer valuable
opportunities for many holders of traditional IRAs to take advantage of
long-term income tax savings, during their own lifetimes and potentially even
during the lifetimes of their heirs.
These benefits are especially pronounced when the converted IRA is
allowed to grow for an extended period of time due to delayed distributions
and/or an account owner's relatively early age at the time of the Roth
conversion. In addition, the benefits of
a Roth conversion are especially significant in the context of - and sometimes
dependent upon - the owner paying the income tax attributable to the conversion
with non-IRA assets. Moreover, changes
in tax rates (whether on an individual level or across-the-board) have a
significant impact on the financial outcome of a Roth IRA conversion and
therefore should be taken into account to the extent possible.
For some individuals, converting to a Roth IRA is clearly an
excellent opportunity for tax savings, while the calculation for others
involves much more speculation. In any
event, it is important to look closely at one's personal circumstances - preferably
with the assistance of a financial advisor who can provide individualized
projections - to determine whether a Roth IRA conversion is likely to be
beneficial. In addition, those
individuals wishing to utilize Roth IRAs as vehicles for testamentary gifts
should consult with their estate planning advisors to ensure that this
objective is aligned with their other estate planning objectives and that
beneficiary designations - particularly where a trust is involved - are
completed in a manner that maximizes the benefits of the Roth IRA conversion.
* * *
Morrison & Foerster's Trusts and Estates group provides
sophisticated planning and administration services to a broad variety of
clients. If you would like additional
information or assistance, please contact Patrick McCabe at (415) 268-6296 or
PMcCabe@mofo.com.
© Copyright 2010 Morrison & Foerster LLP. The views expressed in this
article are those of the author only, are intended to be general in nature, and
are not attributable to Morrison & Foerster LLP or any of its clients. The
information provided herein may not be applicable in all situations and should
not be acted upon without specific legal advice based on particular situations.
This article is published with permission of Morrison
& Foerster LLP. Further duplication without the permission of Morrison
& Foerster LLP is prohibited. All rights reserved. The views expressed in
this article are those of the authors only, are intended to be general in
nature, and are not attributable to Morrison & Foerster LLP or any of its
clients. The information provided herein may not be applicable in all
situations and should not be acted upon without specific legal advice based on
particular situations.
[1] These respective amounts reflect the current
limits, which have increased incrementally over time under Internal Revenue
Code section 408A(c). These reflect the
maximum limits; contributions are phased out at modified adjusted gross incomes
of $166,000 and $105,000, respectively.
[2] Contributions to a traditional IRA that were
not tax deductible are not included in taxable income upon a Roth
conversion. However, where an individual
has made both deductible and nondeductible IRA contributions, he or she must
treat a pro rated portion of any amount converted to a Roth IRA as taxable
income, regardless of which IRA account is converted. This article's analysis assumes that a
converted traditional IRA will have been funded with deductible
contributions. However, where
non-deductible IRAs are involved, the reduction or absence of a conversion tax
weighs in favor of a Roth IRA conversion.
[3] See
U.S. Treas. Reg. §1.401(a)(9)-4.
[4] Bernstein Global Wealth Management, Roth to Riches? Determining Whether a Roth
Conversion Makes Sense (2009) at 11.
See also, e.g., Trytten, Show Me the Money: What's the payoff for
converting to a Roth IRA?, 148 Trusts & Estates 9, at 34.
[5] Id.
[6] Available
at http://www.archimedes.com/vanguard/roth/RothConsumer.phtml.
[7] See, e.g., Bernstein, supra note 4, at 3.
[8] Id.
at 10.
[9] See
Id. at 4-6.
[10] Id.
at 4.
[11] See
Trytten, supra note 4, at 44-46.
[12] See
Steiner, Before Setting Up a Trusteed IRA
and Morrow, Trusteed IRAs: An Elegant
Estate Planning Option, 148 Trusts & Estates 9, at 48 and 53.
[13] Hoyt, Want
to Convert To a Roth IRA?, 148 Trusts & Estates 9, at 31.
[14] Bernstein, supra note 4, at 11.