The formulas
- Account open at least 15 years
- Allowed = lesser of request, contributions and earnings older than 5 years, annual IRA limit less other IRA contributions, $35,000 less prior rollovers
- 2026 IRA limit: $7,500, or $8,600 at age 50 or older
How it works
Section 529(c)(3)(E), effective for distributions after 2023, lets a 529 plan roll to a Roth IRA for the beneficiary without tax when the account has been maintained for 15 years. Contributions made in the last 5 years and their earnings cannot be rolled. The rollover must be a direct trustee-to-trustee transfer.
Each year the rollover is limited to the Roth contribution limit under Section 408A(c)(2), reduced by other IRA contributions for the beneficiary that year, and lifetime rollovers are capped at $35,000. Notice 2025-67 sets the 2026 IRA limit at $7,500 with a $1,100 catch-up at age 50.
Illustrative figures only. Check the result against your firm's methodology before relying on it.
Common questions
Can recent contributions be rolled?
No. Contributions made in the 5 years before the rollover, and their earnings, are excluded.
Does the rollover use the annual IRA limit?
Yes. It is capped at the Section 408A(c)(2) limit less other IRA contributions for the beneficiary that year.
Is the rollover taxable?
No, when all conditions are met it is not included in income.
Sources
- 26 U.S.C. 529, Qualified tuition programs (LII)
- IRS Notice 2025-67, 2026 amounts relating to retirement plans and IRAs
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