Changes in 2010 may create a tax planning opportunity for taxpayers with a traditional individual retirement arrangement (IRA). The Tax Increase Prevention and Reconciliation Act of 2005 eliminates the $100,000 adjusted gross income (AGI) limit for converting a traditional IRA into a ROTH IRA effective January 1, 2010. However, the rules governing conversions are complex, as is the individual conversion decision. Careful planning can result in significant long term appreciation of after-tax wealth. Mistakes, however, can lead to a significant tax bill, a significantly limited retirement and/or estate.