I have a new client we are bringing on board who has an IRA worth $200,000, $40,000 of which represents non-taxable contributions. He is 60 years old and participates in a 401k worth about $1,500,000 and has $65,000 of post-tax contributions in his 401k plan. His 401k plan allows in-service distributions at age 59 and 1/2. He anticipates working 3-5 more years. To avoid pro-rata rule, if we move the $160,000 to his 401k plan from the IRA leaving $40,000 in his IRA and then convert that $40,000 to a Roth IRA, can we turn around and move the $1,500,000 from his 401k to his two IRAs – $65,000 to his new Roth IRA and $1,435,000 to a traditional IRA? Can this be done in the same tax year without triggering the pro-rata rule? If we can do this, then the advantage would be that future earnings in the Roth IRA (about $105,000) would be tax-free instead of taxable inside the current IRA and 401k plan.