Can You Convert an RMD to a Roth IRA? Order and Tax Rules

You cannot convert an RMD to a Roth IRA. Federal law treats a Roth conversion as a rollover, and 26 U.S.C. § 408(d)(3)(E) specifically prohibits rolling over any amount that satisfies a required minimum distribution.¹ The workaround is simple in principle: take your full RMD as a taxable distribution first, then convert whatever additional traditional IRA money you want into a Roth. Roth conversions have no income limit, so this route stays open no matter how much you earn.

Why the RMD Itself Can’t Go Into a Roth

A conversion uses the same plumbing as a rollover, and the tax code carves the RMD out of what’s eligible to be rolled anywhere. Section 408(d)(3)(E) is unambiguous on that point.¹ If RMD dollars do end up inside a Roth, the IRS treats them as an excess contribution and applies a 6% excise tax for every year they stay there.²

The rule that most often trips people up is the first-dollar rule. The IRS treats the first dollars leaving your traditional IRA in an RMD year as the RMD, regardless of what you called the withdrawal.² You cannot label a January transfer a “conversion” and plan to take the RMD in December. The mandatory distribution is assumed to come off the top.

An example makes this concrete. Say your RMD is $15,000 and you want to move $30,000 into a Roth. If you send $30,000 straight to the Roth without first pulling the RMD, the IRS deems the first $15,000 to be your RMD, which means $15,000 of Roth contributions were never legally allowed. That $15,000 becomes an excess contribution accruing the 6% tax until you remove it along with attributable earnings.

The Correct Sequence

Take the RMD first, then convert. Withdraw your full required amount as a normal distribution into a taxable bank or brokerage account. Only after that money has left the IRA can you convert additional dollars to a Roth. Same-week timing is fine as long as the RMD clears first; order matters more than the calendar spacing.

Your custodian reports each transaction on Form 1099-R, and you document the conversion on Part II of Form 8606 with your tax return.³

Once the RMD is satisfied, there is no cap on how much of the remaining balance you can convert, and the income phase-outs that block direct Roth contributions at higher earnings levels do not apply.⁴ Someone earning $300,000 who cannot make a direct Roth contribution can still convert $500,000 in a single year. The full converted amount is added to your ordinary income for the year, which can push you into a higher bracket, raise your Medicare premiums two years out through income-related surcharges, and increase the taxable share of your Social Security benefits. Running the numbers before pulling the trigger is the whole game.

If You Have More Than One IRA

The IRS requires you to calculate the RMD for each traditional IRA separately, but you can take the combined total out of any one of them.⁵ That flexibility helps if you want to convert an entire smaller IRA to a Roth: satisfy your total IRA RMD from a different account, and the account you want to convert is free of any RMD obligation itself.

Workplace plans do not work this way. Multiple 401(k)s each require a separately calculated and separately withdrawn RMD; you cannot use one to cover another.⁵ Multiple 403(b) accounts can be aggregated like IRAs.

The Tax Bill on the Conversion

Everything you convert counts as ordinary income for the year. If your traditional IRA holds both deductible and nondeductible contributions, the pro-rata rule determines the taxable share based on the ratio of pre-tax to after-tax money across all your traditional IRAs, so you cannot cherry-pick the after-tax dollars.⁴

Watch the Withholding

Custodians default to 10% federal withholding on IRA distributions unless you elect otherwise. On a conversion, that default backfires. If you send $50,000 to the Roth with 10% withheld, only $45,000 actually lands there, but the full $50,000 is still taxable as a distribution to you. The $5,000 withheld effectively came out of what could have been Roth money.

Electing zero withholding on the conversion and paying the tax from a separate account keeps the full amount inside the Roth. Just make sure your total payments for the year still hit a safe harbor: 90% of current-year tax or 100% of prior-year tax, whichever is smaller, with the prior-year threshold rising to 110% if your prior-year AGI exceeded $150,000.⁶ Miss the safe harbor and you owe an underpayment penalty on top of the tax.

The 5-Year Rule

Qualified, fully tax-free Roth withdrawals require the account to have been open at least five tax years.⁴ At RMD age you are well past 59½, so converted principal can come out anytime without penalty. Earnings are the concern. If this is your first Roth, earnings pulled within the first five tax years are taxable. If you already have a Roth that has been open five years or more, a new conversion does not restart that clock for earnings.

Penalties for Getting the Order Wrong

Two different penalty regimes apply here, and they can stack.

Miss your RMD and the IRS imposes a 25% excise tax on the shortfall, dropping to 10% if you correct it within two years.⁷ The penalty is reported on Form 5329. Your first RMD is due April 1 of the year after you turn 73; every RMD after that is due December 31.⁸ Waiting until April for the first one puts two distributions in the same tax year.

If RMD dollars accidentally land in the Roth, the 6% excess-contribution excise tax accrues every year they remain there.² The fix is to remove the excess along with attributable earnings before your tax filing deadline including extensions. Miss that window and the 6% keeps compounding annually until the money comes out.

Two Boundaries Worth Knowing

Inherited traditional IRAs work differently depending on your relationship to the original owner. A surviving spouse can roll an inherited IRA into their own IRA and then convert on the same RMD-first terms. Non-spouse beneficiaries cannot convert an inherited traditional IRA to a Roth at all; their options are limited to trustee-to-trustee transfers into an inherited IRA. If you recently inherited an account, confirm your status before assuming a conversion is available.

A separate path exists that isn’t a conversion: take the RMD as cash and then use that cash to make a regular Roth IRA contribution. The catch is that Roth contributions require taxable compensation at least equal to the contribution, and most retirees taking RMDs don’t have earned income.⁹ If you or a jointly filing spouse do have wages or self-employment income, the 2026 IRA contribution limit is $7,500, or $8,600 at age 50 or older with the $1,100 catch-up. Full Roth eligibility for 2026 phases out between $153,000 and $168,000 of MAGI for single filers and between $242,000 and $252,000 for married couples filing jointly.¹⁰ This route moves much less money than a conversion, but it can supplement one.

1
Office of the Law Revision Counsel. 26 USC 408 – Individual Retirement Accounts
2
Internal Revenue Service. Roth Conversions/Retirement Planning for Life Events
3
Internal Revenue Service. Instructions for Form 8606 – Nondeductible IRAs
4
Office of the Law Revision Counsel. 26 USC 408A – Roth IRAs
5
Internal Revenue Service. RMD Comparison Chart (IRAs vs. Defined Contribution Plans)
6
Office of the Law Revision Counsel. 26 USC 6654 – Failure by Individual to Pay Estimated Income Tax
7
Internal Revenue Service. Retirement Topics – Required Minimum Distributions (RMDs)
8
Internal Revenue Service. Retirement Plan and IRA Required Minimum Distributions FAQs
9
Internal Revenue Service. Retirement Topics – IRA Contribution Limits
10
Internal Revenue Service. 401(k) Limit Increases to $24,500 for 2026, IRA Limit Increases to $7,500