A Roth conversion in your first RMD year is allowed, but only in a fixed order: the year you turn 73, your entire required minimum distribution must leave the traditional IRA before any dollar is converted. The first dollars out are legally the RMD, which can never be converted, so converting too early recasts that amount as an excess Roth contribution.
Yes, you can do a Roth conversion in the same year as your first RMD, but you must withdraw the full required minimum distribution first. In an RMD year the first dollars out of a traditional IRA are deemed the RMD, and an RMD can never be converted. Only amounts above the satisfied RMD are eligible to convert, with no dollar cap and no income limit.
What changes the year you turn 73?
The year you reach RMD age, currently 73 for those born 1951 to 1959, adds one rule: the required minimum distribution must come out first. A conversion is still permitted that year and every year after, but only once the RMD is satisfied. This single transitional year, where the 2026 RMD rules first bind, is where sequencing mistakes happen.
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Can you still convert to a Roth after RMDs begin?
Reaching RMD age does not close the door on Roth conversions; it reorders them. Once the RMD is out, additional traditional IRA dollars remain eligible to convert with no dollar cap and no income limit, and many retirees continue partial conversions into their 70s and 80s. Q3’s Roth conversion overview covers the broader tradeoffs; this page stays scoped to the first RMD year.
Quick definitions: RMD, Roth conversion, first-dollars-out
Three terms drive the first-RMD-year decision, each defined under SECURE 2.0 and IRS Publication 590-B: the required minimum distribution, the Roth conversion itself, and the first-dollars-out rule that orders them. Their interaction sets the exact sequence you must follow in the year you turn 73, so pin down each one before you move any money.
- RMD (required minimum distribution): the minimum you must withdraw yearly from a traditional IRA at RMD age, set by the Uniform Lifetime Table in IRS Publication 590-B (the age-73 divisor is 26.5).
- Roth conversion: moving pre-tax traditional IRA dollars into a Roth IRA. The amount is taxable ordinary income that year, and since 2018 it is irreversible.
- First-dollars-out rule: in any RMD year, the first dollars distributed are deemed to satisfy the RMD before anything else, including a conversion.
Do you have to take your RMD before a Roth conversion?
Yes. The IRS first-dollars-out rule governs the whole year: the earliest dollars leaving a traditional IRA in an RMD year are treated as the required minimum distribution, and an RMD is never eligible to be rolled over or converted. The full RMD must be distributed and kept (it is taxable) before any dollar moves into a Roth.
Worked example: $40,000 RMD then $60,000 conversion
An illustrative retiree with a $40,000 RMD who wants $60,000 in a Roth takes the $40,000 RMD first (taxable, stays outside the Roth), then converts $60,000 (also taxable, and this lands in the Roth). Both are ordinary income, so $100,000 leaves the IRA but only $60,000 reaches the Roth, as the table shows.
| Step | Amount | Taxable? | Where it lands |
|---|---|---|---|
| 1. Take the full RMD first | $40,000 | Yes | Taxable account or spending (never the Roth) |
| 2. Then convert the extra | $60,000 | Yes | Roth IRA |
| Total leaving the IRA | $100,000 | All ordinary income | $60,000 into the Roth |
How does the RMD work if you hold several traditional IRAs?
With more than one traditional IRA, the RMD is calculated separately for each account, then aggregated into one total. You may withdraw that total from any single IRA or split it, a point the IRS confirmed in the July 2024 final SECURE Act regulations. The full aggregated RMD must be satisfied before you convert from any of them; clearing one account does not free another.
What happens if you convert before taking your RMD?
Convert before the RMD is out and the tax code does not simply relabel the transaction. Because the first dollars out were legally the RMD, the portion of the conversion equal to the untaken RMD becomes an excess contribution to the Roth IRA, a separate problem from the conversion tax that repeats every year until you fix it.
The recurring 6% excess-contribution penalty and how to fix it
An excess Roth contribution draws a 6% excise tax on the excess for each year it stays in the account, so the 6% applies again every year it remains. The fix is a timely removal of the excess plus any attributable earnings, generally by the tax-filing deadline including extensions. Because the mechanics are technical, first-year conversions often warrant a tax professional.
The first-year April 1 deadline and your conversion window
Only your very first RMD can be deferred. Instead of the usual December 31 deadline, the first year’s RMD may be delayed until April 1 of the year after you turn 73. Every RMD after that, including the second, is due by December 31. That one-time deferral interacts with conversions in ways worth weighing before you use it.
How deferral interacts with a conversion
Deferring the first RMD does not create extra Roth room in your turning-73 year; you can still convert on top of dollars you actually withdraw. But the deferred RMD does not disappear: it must be satisfied the year you take it, where the first-dollars-out rule applies again. The Roth conversion deadline in 2026 matters for sizing a year-end move.
Why some advisors say don’t defer the first RMD
A common approach is to take the first RMD on time rather than defer it. Deferral pushes RMD number one into the same calendar year as RMD number two, stacking two full distributions into one year. Taking RMD number one on schedule keeps them in separate tax years and preserves a cleaner runway for a first-year conversion.
The two-RMD trap that can wreck a first-year conversion
Here is the trap most competitors skip. Defer your first RMD to April 1 and you take both RMD number one and RMD number two in the same following calendar year. Two full required distributions land in one tax year, and any conversion sits on top, which can push a retiree into a higher bracket with effects beyond that year’s income tax.
Bracket, Social Security, and the IRMAA two-year ripple (2026 tiers)
Stacking two RMDs plus a conversion raises modified adjusted gross income three ways: it can push income into a higher federal bracket (the 24% bracket runs to $201,775 single and $403,550 married filing jointly in 2026), make up to 85% of Social Security benefits taxable, and raise Medicare Part B and Part D premiums two years later through the income-related monthly adjustment amount (IRMAA).
| 2026 IRMAA tier (MAGI two years prior) | Single MAGI | Married filing jointly MAGI | Monthly Part B premium |
|---|---|---|---|
| Standard (no surcharge) | $109,000 or less | $218,000 or less | $202.90 |
| Tier 2 | $109,000 to $137,000 | $218,000 to $274,000 | Standard plus surcharge |
| Tier 3 | $137,000 to $171,000 | $274,000 to $342,000 | Standard plus surcharge |
| Tier 4 | $171,000 to $205,000 | $342,000 to $410,000 | Standard plus surcharge |
| Tier 5 | $205,000 to $500,000 | $410,000 to $750,000 | Standard plus surcharge |
IRMAA operates as a cliff: crossing a threshold by one dollar moves you into the next tier for the whole year, so a doubled-RMD-plus-conversion year deserves a MAGI projection before December 31. The last conversion year that no longer affects any Medicare premium is age 62, because of the two-year lookback.
Defer vs. take-now decision framework
Deferral tends to help in narrow cases and backfire in common ones. It may suit a retiree with little other income in the turning-73 year who wants to shift the first RMD into a lower-income future year. It backfires for someone near a bracket edge or an IRMAA threshold, where two RMDs plus a conversion can vault a tier.
| Factor | Defer first RMD to April 1 | Take first RMD on time (by Dec 31) |
|---|---|---|
| RMDs in the following year | Two (RMD 1 and RMD 2 stack) | One (RMDs stay in separate years) |
| Effect on a first-year conversion | Squeezes conversion room in year two | Cleaner conversion runway each year |
| Bracket and IRMAA risk | Higher in the doubled-up year | Spread more evenly across years |
| May suit | Very low income in the turning-73 year | Income near a bracket or IRMAA edge |
Sizing the conversion against remaining bracket room, covered in Q3’s guide on how much to convert to a Roth, is where the real planning happens.
Your first-RMD-year order of operations
A reliable path through the transitional year is a fixed sequence: confirm the first RMD year, calculate the amount, decide the timing, take the full RMD, and only then convert. Projecting full-year MAGI last lets a conversion be sized against brackets and IRMAA tiers before the December 31 deadline.
- Confirm the RMD age. Born 1951 to 1959, RMDs start at 73. Born 1960 or later, at 75 (earliest age-75 RMD year is 2035).
- Calculate the aggregated RMD. The Uniform Lifetime Table (divisor 26.5 at age 73) applies across all traditional IRAs.
- Decide defer versus take now. Weigh the April 1 deferral against the two-RMD trap.
- Withdraw the full RMD and keep it before a conversion begins.
- Then convert the extra. Only dollars above the satisfied RMD move into the Roth.
- Project MAGI. A break-even analysis can frame whether the conversion tax is worth paying now.
Work with Q3 Advisors
Q3 Advisors is a registered investment adviser focused on retirement tax planning. This page is educational and is not advice; consult a qualified professional.
Frequently asked questions
Can you do a Roth conversion in the same year as an RMD?
Yes, you can do a Roth conversion in the same year as an RMD, as long as you take the full required minimum distribution first. The first dollars out of a traditional IRA in an RMD year are deemed the RMD, which can never be converted. Once it is satisfied, amounts above it convert freely, with no dollar cap and no income limit.
Do you have to take your RMD before doing a Roth conversion?
Yes. The IRS first-dollars-out rule treats the earliest dollars leaving the IRA in an RMD year as the required minimum distribution, and an RMD cannot be rolled over or converted. The entire RMD must be withdrawn and kept before any dollar is eligible to convert. With multiple IRAs, the full aggregated RMD must be satisfied first.
Does a Roth conversion count toward your RMD?
No. A conversion never counts toward satisfying your RMD, and an RMD can never be converted; they are separate transactions. In an RMD year the required distribution must be withdrawn first and stays outside the Roth. For the full walkthrough, see Q3’s companion explainer on whether a Roth conversion counts as an RMD.
Can you convert your RMD to a Roth IRA?
No. An RMD can never be converted to a Roth IRA. The required minimum distribution must leave the traditional IRA as a taxable withdrawal and stay outside the Roth. Convert an amount equal to the untaken RMD and the tax code recasts it as an excess Roth contribution subject to a recurring 6% excise tax. Only dollars above the RMD are convertible.
What happens if you do a Roth conversion before taking your RMD?
Converting before the RMD is satisfied creates an excess Roth contribution equal to the untaken RMD. That excess draws a 6% excise tax, and the 6% recurs at the end of every year it remains in the account. You correct it by timely removing the excess plus any attributable earnings, generally by the tax-filing deadline including extensions.
Is there an income limit on Roth conversions after age 73?
No. A Roth conversion has no income limit and no dollar cap at any age, including after 73. The income phase-outs apply only to direct Roth contributions ($153,000 to $168,000 single and $242,000 to $252,000 married filing jointly in 2026), not to conversions. After the RMD is satisfied, you may convert any additional traditional IRA amount, taxable as ordinary income that year.
