A Tax-Free Roth Conversion Question of Timing

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We’ve discussed here in the past about how it is (at least under present law) a perfectly legal maneuver to make a non-deductible contribution to a traditional IRA and then at some point later convert the same contribution to your Roth IRA (see Is it Really Allowed? for more).  If you have no other IRA accounts, this conversion to Roth can be a tax-free event, especially if there has been no growth or gains in the investments in the account.

However (and there’s always a however in life) I recently came across a situation that was sent to me by a reader, where he wanted to do such a conversion, but he also wanted to rollover some money from his 401(k) plan into an IRA.  The question is in the timing – understandably, if he does the conversion from the traditional IRA to the Roth IRA, there will be no tax on the conversion, since he doesn’t have any other IRA accounts.

As we know, when taking distributions from an IRA (such as for a conversion) the taxability of the distribution depends upon the total amount of money in all IRAs, and how much is pre-tax versus how much is post-tax.

Here’s an example: Joe has an IRA with deductible contributions of $4,000 and subsequent growth of $1,000.  He is no longer eligible for deductible contributions to his account, and he also is not eligible for contributions to a Roth IRA, both due to his income level.  He wants to make a non-deductible contribution of $5,000 to the IRA and then later convert the money to his Roth IRA.  When he does the conversion, his $5,000 conversion will be partly taxed – since half of his total IRA is non-deductible contributions, every dollar he converts is 50% taxed, and 50% tax-free.

So, if Joe did the same thing except that he starts out without an IRA, and when he converts $5,000 from his traditional IRA to the Roth IRA, the entire amount of the conversion will be tax-free. Maybe.

Back to the question that the reader posed. What happens, tax-wise, if he does the non-deductible contribution and then later converts the money to Roth, and then later in the same tax year he rolls over his 401(k) plan into an IRA?

Here’s what happens: The Roth Conversion will be partly taxable.  Let’s say the 401(k) rollover is for $10,000.  At the end of the year, when the taxpayer files his tax return he’ll include a Form 8606.  On Form 8606 will be a determination of the amount of his distribution(s) from his IRA that is deemed non-taxable for the year.  This is done by developing a fraction against which his distributions are multiplied.  The fraction is as follows:

Total Non-Deductible Contributions / (Year-End Account Balance + Distribution Amounts + Outstanding Rollovers Not Yet Completed)

The key to this equation that makes his Roth Conversion partly taxable is the fact that the divisor of the equation includes his Year-End Account Balance – not the account balance at the time of his conversion.

So, in the reader’s question, the equation looks like this:

$5,000 / ($10,000 + $5,000 + 0) = 33.33% or 1/3

In other words, only 1/3 of the conversion amount will be tax-free given the circumstances.  If the rollover from the 401(k) plan is delayed to the following tax year, the full amount of the conversion distribution would have been tax-free, all other things remaining the same.