Roth Convertine FIAs during income payout phase

Hi Everyone, I have a wholesaler telling me that I can start income on his lifetime income FIA, and with the way it is designed, can do a full Roth conversion when the actual account value is almost exhausted (about year 10 in his illustrations). This would cause a minimal tax hit for the client (say you convert to Roth when there is only $5k – $10k of actual account value left) and then the income would continue for life (one or two participants) and the rest of the lifetime income would be tax-free (since it is not a Roth). Has anyone heard of this strategy or is doing it? Can this really be done? Seems a bit too good to be true? Thanks in advance.



  • The fair market value of a converted annuity as reflected in your 1099R is determined by which of 3 methods the insurance company chooses to apply per the applicable IRS Reg per QA 14 of the following IRS Reg. All of these methods are likely to result in a higher fair market value of the annuity than the cash value at the time of the conversion. You should get a quote from the company on what that value will be before converting.
  • 26 CFR § 1.408A-4 – Converting amounts to Roth IRAs. | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute (cornell.edu)
  • Generally, the IRS Regs produce a higher FMV for conversion than for IRA RMD purposes if not converted. If the conversion is done in an RMD distribution year, the RMD must be completed for all non Roth IRAs prior to any conversions.


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