5 year rule on ROTH Conversions

I have a client who is 65 years old and opened a ROTH IRA in 2017 with $25k. (this is his only ROTH IRA he has) He did a $50k ROTH Conversion in December of ’21 and another $50k ROTH conversion in December of 2022.

He is buying a summer home and wants some cash for a down payment. I know he can take the first $25k out tax free as he has met his 5 year window and is over 59 1/2. My question is, are the two $50k conversions also able to be taken out tax free or does each one have a new 5 year window. I don’t want him to take a distribution and then have there be taxes on top of this so I want to make sure I give him the correct information.

Thank you in advance for your help.



Any distribution taken will be tax and penalty free. Conversion 5 year holding periods all end at 59.5, therefore the entire Roth balance is available without tax or penalty. If client is retired and in a lower bracket, it would make more long term sense to take some of this distribution from a TIRA and preserve more of the Roth. 



Thanks.  He doesn’t want to take money from his TIRA as this adds income to year end totals and increases his medicare payments.  Trying to keep income down as he has a nice pension and dividend income from UPS where he worked. 



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