I have an elderly client who cannot convert an IRA to a Roth because the RMD with the other income excedes the 100,000 threshold.
What to you think of this continual strategy?
1) Each year at the beginning of the year convert the IRA to a Roth IRA delaying the withdrawal of the RMD,
2) At the end of the year (if the client is still living) recharacterize the Roth back to a traditonal IRA and take out the RMD,
3) Continue this strategy until the year of death. As long as death occurs before the last half of December, the Roth conversion could stand since the RMD would not be included on the final return.
Does anyone see any problems with this strategy? (I realize that the RMD in the year of 70.5 cannot be delayed for purposes of meeting the 100,000 threshold, but this strategy is different.)

I don't believe this strategy would work since technically a Roth conversion is a "distribution" and a "rollover" and the RMD is not ever eligible to rollover, even after the 70.5 year. You end up making an excess Roth IRA conversion contribution under this strategy.