15 years Roth conversion rule for 529 rolled over from another state

[agalkin]

How does 15 year Roth conversion rule apply to the accounts that were rolled over from one state to another? Say 529 account was in one state for 10 years and rolled over to another state and I have it for another 11 years in this new state. Is this account considered a 21 year old account for Roth conversion?

[Mark_Kantrowitz_SFC]

The statutory language on page 858 of the SECURE 2.0 Act states "In the case of a distribution
from a qualified tuition program of a designated beneficiary which has been maintained for the 15-year
period ending on the date of such distribution."

As you can see, there is some ambiguity in the language. The IRS will need to issue guidance to clarify, but has not yet done so.