Roth conversions on annuities with income riders

I think I am clear on the conversion rules but would like verification!

I will be converting IRA funds over a 4 year period and the converted funds will be in annuities with income riders. The breakdown is as follows:

250k converted in 2023 will fund an annuity with an income rider issued in January of 2024.

250k converted on January 2nd 2024 will fund an annuity with an income rider that will be issued after the conversion.

250k (minus 1 years of income from the annuity) will be converted on January 2nd 2025 from an annuity with income rider funded in 2024.

250k (minus 2 years of income from the annuity) will be converted on January 2nd 2026 from an annuity with an income rider funded in 2024).

In short, we are applying for 4 separate annuities with income riders, and converting each one in it’s entirety over four calendar years with 2023 and 2024’s conversions taking place before the annuities are issued and 2025 and 2026 conversions taking place post annuity issue.

The income benefits from all 4 annuities will begin immediately after issue (in Jan/Feb 2024). I understand the value used to determine the taxable amount on the conversion will be based on an actuarial calculations considering both the market value of the contract plus the actuarial present value of the benefits.

My question is as long as the client does not withdrawal more than the taxable amount of the conversion with in the 5 year window, will all the withdrawals received be conversion amounts based on IRS Roth withdrawal order rules, therefore not subject to taxation. Stated differently, will payments to the client be considered “earnings”, only after the converted amount has been fully withdrawn?

Thank you in advance!!!



  • Yes, the Roth IRA ordering rules trump the usual NQ annuity distribution rules. The 1099R for each year’s conversions should be retained to document the conversion basis reported on line 24 of Form 8606. However, if client is under 59.5, there will be a 10% recapture tax on distributions from any taxable conversions not yet held the required 5 years. 
  • There are 3 different methods the insurance company can choose from to calculate the conversion value for the third and fourth conversions, but it’s unlikely that the company would be willing to run the numbers to determine the lowest. 
  • Of course, there will be RMD considerations once client reaches RMD age if there are any remaining TIRA funds. At that time the entire RMD must be completed for all non Roth IRA accounts before any conversion is executed. 

The client turns 68 this year so we will have all conversions complete by the time RMDs are taken.  I just want to take a side moment and say thank you for your prompt and detailed responses to questions from the community. You are an amazing resource that allows us to have confidence in dealing some of the subject matter we do. THANK YOU!!!

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