FACTS:

Client age 60

401k after-tax contribution balance $45,000

401k earnings on after-tax contributions $15,000

401k Total Value $1,000,000

401k plan allows automatic daily in-plan Roth conversions

401k plans allows rollover of existing after-tax contribution balance to outside Roth IRA, and allows the rollover of the earnings on the after-tax contributions to an outside Traditional IRA

STRATEGY:

Client intends to elect automatic daily in-plan Roth conversion for all future after-tax contributions.

Before client makes this election, they will rollover their existing after-tax contribution balance to an outside Roth IRA and the earnings on the after-tax contributions to an outside Traditional IRA.

With this process, client expects minimal or no income tax triggered on future in-plan Roth conversions since there will be little or no opportunity to generate earnings because of the automatic daily processing.

QUESTION:

Now assume

1. Client does not rollover existing after-tax contributions to Roth IRA and earnings on after-tax contributions to Traditional IRA

2. Client elects automatic daily in-plan Roth conversion for all future after-tax contributions (not existing balances)

In this scenario, given the 45k of after-tax contributions and 15k of earnings on the after-tax contributions residing in the plan, will any tax be triggered on future automatic daily in-plan Roth conversions related to the 15k of earnings?

Thank you.