If ever I was traveling from Los Angeles to Atlanta, I would choose a direct flight with no layovers. I want the most efficient route to my destination. Point A to Point B. Take off, land. Assuming no difference in ticket price and all things being equal, if another LAX to ATL itinerary included a stop in, say, Chicago, would there be any reason to take it? Why pass through another airport in another city when I can fly direct? If I have no personal or professional business in Chicago, it makes no sense for me to go there. A layover in Chicago does nothing but add time, introduce possible delays, and create the risk of a missed connection. Like flying direct, “mid-air” conversions can save time and minimize potential problems. If there is no reason for a layover in a traditional IRA, then why do it?

Streamlining Rollovers from Work Plans to IRAs

Rollovers from work plans like a 401(k) to an IRA are as common as air travel. Typically, individuals move pre-tax dollars into a traditional IRA. Then, they roll any Roth dollars in the work plan into a Roth IRA. These are straightforward transactions. But what about after-tax (non-Roth) dollars that may exist in a work plan? (Some plans allow after-tax contributions.) When individuals roll after-tax dollars out of the work plan, they can choose to transfer them to either a traditional IRA or a Roth IRA. In fact, even standard pre-tax plan dollars can roll to either a traditional or Roth IRA.

The Convenience of Direct Roth Conversions

Historically (assuming no in-plan conversion prior to the rollover), if a person wanted to convert after-tax (non-Roth) or pre-tax plan dollars to a Roth IRA, those dollars first had to be routed through a traditional IRA. Once in the traditional IRA, they could then be converted to their final destination – a Roth IRA.

No longer is this the case. As part of the Pension Protection Act of 2006, Roth conversions can be done directly from company plans. Just like a person can fly directly from LAX to ATL and avoid a layover in another city, after-tax and pre-tax 401(k) dollars can take off from the plan and land directly in a Roth IRA. This is a valid conversion. While a direct rollover to a Roth IRA is not subject to 20% withholding, be aware that pre-tax assets rolled over are includable in income. (Note that if a plan participant elects to do a 60-day rollover, where the check is made payable to the participant, the 20% withholding is mandatory.)

Pro-Rata Concerns

Thankfully, such “mid-air” or “in-flight” Roth conversions are permitted. While routing pre-tax 401(k) plan dollars through a traditional IRA requires an extra step (a “layover” in the traditional IRA), no other major issues typically present themselves. However, routing after-tax (non-Roth) monies through a traditional IRA creates, potentially, more obstacles. For example, the pro-rata rule dictates that a person cannot simply cherry-pick the after-tax dollars in their IRA and only convert those. If after-tax dollars are commingled with pre-tax funds in a traditional IRA, pro-rata becomes a significant and ongoing concern. While there are ways to deal with the pro-rata rule, a “mid-air” tax-free conversion of after-tax dollars eliminates any pro-rata worries.

Like flying direct, “mid-air” conversions can save time and minimize potential problems. If there is no reason for a layover in a traditional IRA, then why do it? Pre-tax and after-tax dollars can take a direct route from the plan to a Roth IRA. Of course, converted pre-tax dollars are added to income, so be sure you have the money to pay the taxes due on the conversion. Planes can’t fly backward, so there is no way to reverse the transaction.


By Andy Ives, CFP®, AIF®
IRA Analyst

Copyright © 2023, Ed Slott and Company, LLC Reprinted from The Slott Report, 2022, with permission. Ed Slott and Company, LLC takes no responsibility for the current accuracy of this article. Content posted in Ed Slott’s IRA Corner was developed and produced by Ed Slott & Co. to provide information on a topic that may be of interest. Ed Slott and Ed Slott & Co. are not affiliated with Ethos Capital Management, Inc. The opinions expressed and material provided are for general information and should not be considered a solicitation for the purchase or sale of any security.  The tax information provided is general in nature and should not be construed as legal or tax advice. Information is derived from sources deemed to be reliable. Always consult an attorney or tax professional regarding your specific legal or tax situation. Tax rules and regulations are subject to change at any time. Ethos Capital Management, Inc. is a registered investment adviser. The firm only conducts business in states where it is properly registered or is excluded from registration requirements. Registration is not an endorsement of the firm by securities regulators and does not mean the adviser has achieved a specific level of skill or ability.