Yes, but your twelve year old will be the owner of the account. In addition, you may not want to pay tax on the IRA in one lump sum.  Why not just take minimum distributions (which would likely be small enough to be tax free or taxed at a very low rate) and reinvest those in a 529 plan each year?  As an alternative, the IRA assets themselves can be used for qualified higher education expenses with no penalty.  This would postpone any taxes paid until the child actually used the account for college.