Suppose client had $1000 in his IRA on 12/31/22. He also had a 401(k) balance of $250,000 on that same date.

Now suppose he rolls the 401(k) to the IRA on 1/2/23. Can he then purchase a $200k QLAC?

My understanding is that the 12/31 balances were germane in terms of determining the 25% cap on QLAC premium. With that 25% cap now gone, are the 12/31 balances important anymore, or can the client above make the $200k QLAC purchase in 2023 with the money rolled over in 2023?

Thanks.