My client asked me about recharacterizing their IRA's yesterday so I did some research on it. The CARES Act allows recharacterization during 2020, it appears. They would have to pay tax on the IRA amounts. My question about the tax is, at what rate? The sample says at the 15% rate they would pay $15,000 on a $100,000 exchange. I'm assuming that the rate would be the taxpayer's current rate. The thing is that last year (2019) they had a very good year and were in a high tax bracket, this year thanks to COVID, they will have a loss and likely no tax liability. So it seems this might be a good year to take advantage of recharacterization. Is there a rule that would apply a minimum amount on the exchange?