IRA to Roth IRA conversion with RMD requirement

When an RMD withdrawal is required and one wishes to also convert to Roth IRA, why must the RMD be taken prior to the conversion. I fail to understand the logic (if any) behind this requirement since both transactions are fully taxable.



26 CFR § 1.408A-4 Q&A-6 explains this.  (Be aware that this has not been updated to reflect that the RMD age has been increased to 72.)



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