Roth conversion and distribution

Executive summary: Are distributions from Roth _conversions_ (from traditional IRA) free of tax and penalty if the retiree is at least

59½ and first contributed to the Roth at least 5 tax years ago, without respect to the general five-year rule for conversions?

Details:

I turned 70 in the second half of 2019. I first contributed to my Roth in early 2016 for tax year 2015, and therefore my five-year period ended on January 1, 2020. That means that earnings from my contributions in 2015-2019 could be withdrawn now free of tax or penalty, if I wanted to. (Please correct me if I'm making some boneheaded mistake.)

Now for my question. Since, under the SECURE Act, my first RMD is now due in 2021 and not 2020, I don't need to take an RMD this year. I thought to convert some amount from my traditional IRA into my existing Roth, but I want to make sure I don't fall afoul of the five- year rule for conversions.

As I read Pub 590-B, specifically here:

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Any money I distribute from my Roth would be tax and penalty free, since I am over 59½ and the Roth is over 5 tax years old. The IRS text doesn't seem to say specifically that that applies to conversions. However, the flow chart Figure 2-1 on that page does not make any exception for conversions. I'd like to confirm from the experts here that the five-year rule for conversions doesn't apply after age 59½ if the five-year rule for contributions has been met.

I don't expect to take _any_ money from the Roth within five years after conversion anyway, but if circumstances change and I do need it I'd hate to get hit with a nasty surprise.

(I already know not to convert enough that I'd get hit with an IRMAA by Medicare, and I know that I should pay the income tax on the conversion with regular money, not money from a retirement account. My traditional IRA is several times as large as the Roth, so I'm trying to reduce the imbalance and reduce RMDs for the future.)

And even if all the above is what I think, am I missing something that would make it a bad idea to do that partial Roth conversion?

Reply to
Stan Brown
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Thanks for replying, Ira.

I understand that. I turned 70 in the second half of 2019, and will not be 70½ till the first half of 2020.

Reply to
Stan Brown

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