The House Ways and Means Committee recently passed $2.1 trillion in tax hikes that will help fund President Joe Biden's American Families Plan. Among their proposals are the elimination of backdoor Roth and mega backdoor Roth IRA conversions. Both of these provisions could affect your clients who earn too much to contribute to a Roth IRA and those who want to ramp up their Roth account balances.
Backdoor Roth IRA Strategies
A mega backdoor Roth is a situation where your client can contribute up to $38,500 on an after-tax basis to their employer's 401(k) plan, if the plan allows for these contributions. At some point, your client will roll this money over to an IRA and convert to a Roth IRA plan or to a Roth 401(k) account within the plan if one is offered and in-plan conversions are allowed. Rollovers with a conversion to a Roth IRA would be made either when they leave the company or while they are employed if the plan allows in-service withdrawals.
The backdoor Roth IRA conversion is a technique where investors who earn too much to contribute directly to a Roth IRA make after-tax contributions to a traditional IRA and then convert the contributed amount, and perhaps other money in the account, to a Roth IRA.
Take Action by Year-End
The proposed legislation would end the ability to convert after-tax contributions in both 401(k) plans and traditional IRAs to a Roth after Dec. 31, 2021, effectively killing both of these options.
Clients who have been making after-tax contributions to their 401(k) plan to fund a mega backdoor Roth conversion need to make some decisions this year.
If their plan allows for the conversion of this money to a Roth 401(k) account within the plan, this needs to be done prior to Dec. 31, 2021, if the legislation passes as is. Note that any earnings on these after-tax contributions will be taxable upon conversion. If the plan allows for in-service withdrawals in order to roll this after-tax money to an IRA and convert to a Roth, your client will want to consider doing this by the end of the year.
If none of these options are available to your client, the after-tax contributions would be stuck in the plan until they leave the company. Unless this happens prior to Dec. 31, 2021, they will lose the opportunity to convert this money to a Roth if the proposed legislation passes.
For clients who may want to make an after-tax contribution to a traditional IRA and do a backdoor Roth conversion, this also needs to be done by Dec. 31 of this year if this legislation passes.
10-Year Roth Conversion Window
The proposed legislation contains limitations on conversions of traditional IRA money based on pretax contributions after Dec. 31, 2031. For those earning $400,000 or more (or $450,000 for married filing jointly) the ability to do a Roth conversion will be completely eliminated after this date.
The 10-year window on Roth conversions is a good reason for you and your clients to revisit the timing for Roth IRA conversions to ensure that they are able to convert a desired amount over the next 10 years if they will be in a higher income bracket after the window closes.
Backdoor Roth Alternatives
While there is no way to replicate the backdoor Roth, there are other ways to accumulate assets that won't be taxed in retirement.
Roth 401(k)
