Daniel is 24, has finished his degree, and is the beneficiary of a Section 529 account his parents opened for him nine years ago. It still holds 28,000 dollars, and nothing further will be spent on education. Daniel earned 4,000 dollars in wages this year and has made no Individual Retirement Account contribution. His father asks whether the leftover balance can be moved into Daniel's Roth IRA under the rollover route created by SECURE 2.0. Which response is correct?
- AThe whole 28,000 dollars may be rolled into Daniel's Roth IRA this year, because the governing constraint is the lifetime cap on these rollovers and the account is nowhere near it.
- BNo rollover is permitted this year, because the account has been open for fewer than fifteen years; once it qualifies, each year's transfer is capped by Daniel's earned income and the annual Roth IRA limit, with a 35,000 dollar lifetime cap. Correct
- CUp to 4,000 dollars may be rolled into Daniel's Roth IRA this year, because his earned income for the year sets the ceiling and no further condition stands in the way of the transfer.
- DNo rollover is permitted at any point, because Daniel has left education and the balance can now leave the plan only as a non-qualified distribution taxed on its earnings.
Why A is wrong: The lifetime cap is real but it is not the only constraint; each year's rollover is also limited by the annual Roth IRA contribution limit, so a single transfer of the whole balance is not permitted even for an eligible account.
Why B is correct: Correct: the fifteen year seasoning requirement is a threshold test that this account fails, and the annual and lifetime caps then govern once the account does qualify, so the family must wait rather than transfer now.
Why C is wrong: Earned income does cap the amount once the account qualifies, but this answer ignores the requirement that the Section 529 account has been maintained for at least fifteen years, which this one has not.
Why D is wrong: This describes the position before SECURE 2.0 and ignores the rollover route it created; leaving education does not by itself disqualify a Section 529 balance from moving to a Roth IRA.