Roth Conversion After RMDs Start: What's Still Possible at 73, 76, 80

Required minimum distributions don't end your ability to do Roth conversions — they complicate it. The rules are different, the math is tighter, and the primary reason to convert shifts from rate-differential savings to protecting your heirs. Here's what changes after 73 and how to navigate it.

The short answer: yes, conversions are still legal after RMDs begin

There is no age limit on Roth conversions. A 76-year-old with a $1.5M traditional IRA can convert $60,000 this year, just as they could have at 68. The mechanics are identical: request a distribution from your traditional IRA and roll it into a Roth IRA within 60 days (or direct-transfer it).

But one critical rule applies once you're in RMD territory:

Practical implication: if your RMD is $70,000 and you want to also convert $50,000, you must take the $70,000 RMD distribution as regular taxable income first, then separately convert $50,000 from the remaining balance. You cannot skip the RMD or fold it into the conversion.

What the RMD amounts look like at different ages

Required distributions are calculated by dividing your prior December 31 IRA balance by the IRS Uniform Lifetime Table (ULT) divisor for your age.¹ The divisor shrinks each year, so the RMD percentage of the balance rises.

The RMD is mandatory and taxable. The question for each year: after meeting the RMD, how much additional conversion makes sense on top of it?

The QCD strategy: shrink the taxable RMD, free up conversion room

If you're charitably inclined and age 70½ or older, a Qualified Charitable Distribution (QCD) is one of the most powerful tools available to post-73 retirees.²

A QCD allows you to transfer up to $111,000 directly from your IRA to a qualified charity (in 2026, indexed for inflation).² The key: a QCD counts as satisfying your RMD for the year, but the amount transferred does not appear as taxable income. It never touches your AGI.

The QCD + conversion combination:

1. Use a QCD to satisfy all or part of your RMD — at zero federal income tax cost.
2. Convert additional IRA dollars to Roth up to your available bracket room.
3. Result: smaller taxable income from mandatory distributions, more room for strategic conversions.

QCDs must go directly from the IRA custodian to the charity — you cannot take the distribution yourself and then donate it. Most custodians can facilitate this with a simple form or check made payable to the charity.

Why post-73 conversions still make sense: the heir's bracket argument

The primary math driver for Roth conversion before 73 is rate differential: pay 22% now to avoid 32% later. After 73, your own rate differential may be smaller — your RMD income has already pushed you into a higher bracket, and there are fewer years to compound the Roth balance.

But the heir's bracket argument often survives intact at any age:

• Inherited traditional IRA under the 10-year rule: Non-spouse beneficiaries must empty the account within 10 years of the owner's death and pay ordinary income tax on every distribution (T.D. 10001).³ If your heirs are in peak earning years, they may face 32–37% on those distributions.
• Inherited Roth IRA under the 10-year rule: Same 10-year rule applies, but distributions are tax-free. No annual RMD requirement during the 10-year period (unlike inherited traditional IRAs when the decedent was past their required beginning date).
• The math: If you convert at your marginal rate of 22% and your heirs would have paid 35%, you've transferred 13 cents of every dollar to them instead of the IRS — regardless of your own remaining life expectancy.

See the full estate planning analysis: Roth Conversion as Estate Planning.

Worked example: Frank and Ellen, both 76

Frank holds $1.8M in a traditional IRA. Ellen has a small Roth IRA from prior conversions. They both collect Social Security — $54,000 combined annually, claimed at 70. Both are 65+, filing MFJ.

Step 1: Calculate Frank's 2026 RMD. Prior December 31 balance: $1,800,000. ULT divisor at age 76: 23.7. RMD = $1,800,000 ÷ 23.7 = $75,949

Step 2: Estimate income and bracket position.

• RMD: $75,949
• Social Security combined income test: $75,949 + ($54,000 × 0.5) = $102,949 — well above the $44,000 MFJ threshold,⁴ so 85% of SS is taxable.
• Taxable SS: $54,000 × 85% = $45,900
• AGI: $75,949 + $45,900 = $121,849
• Standard deduction (MFJ, both 65+): $32,200 + $1,650 + $1,650 = $35,500⁵
• Taxable income: $121,849 − $35,500 = $86,349 — in the 22% bracket (2026 MFJ 22% bracket: taxable income $100,801–$211,400).⁵

Step 3: Find conversion room.

• Room to top of 22% bracket: $211,400 − $86,349 = $124,951 taxable income space
• IRMAA ceiling: to avoid crossing the 2026 Tier 1 threshold ($218,000 MAGI for MFJ),⁶ conversion is limited to: $218,000 − $121,849 = $96,151
• The IRMAA ceiling is the binding constraint here — not the bracket ceiling. They can convert up to $96,151 and stay below IRMAA Tier 1.

Step 4: Weigh the decision.

• Federal tax on $96,151 conversion at 22%: approximately $21,153.
• If Frank dies and Ellen becomes a single filer, her standard deduction drops and the 22% bracket for single filers is narrower (top: $105,700 taxable).⁵ Converting now, while MFJ brackets are wide, protects against the widow bracket compression.
• If their two adult children (both high earners) inherit a traditional IRA, they'll owe ordinary income tax at 35%+ on distributions over 10 years. Converting at Frank's 22% saves ~13 points per dollar.

Result: Frank and Ellen choose to convert $60,000 this year — enough to move a meaningful balance to Roth, pay for the tax from their taxable brokerage account, and keep their MAGI safely below $182,000 (well under Tier 1 IRMAA at $218,000).

When post-73 conversion isn't worth it

Post-RMD conversions are not the right move in every case. Skip the conversion (or keep it small) when:

• Your RMD alone already fills the 22–24% bracket. Adding a conversion on top would push you into 32%+ — and the rate differential over your heirs' expected rate may not justify it.
• IRMAA cliffs leave no headroom. If your RMD + SS already puts your MAGI above $218K MFJ / $109K single, you've already hit Tier 1. Each additional $29,000 of MAGI crosses another tier. Converting may cost more in surcharges than in future income tax savings.
• You need all RMD proceeds for living expenses — and don't have outside assets to pay the tax on a conversion. Paying the conversion tax from the IRA itself defeats most of the math.
• Your heirs are in low brackets or charitably minded. If your estate will pass to a 12%-bracket heir or a charity (via QCD or bequest), the inherited-Roth advantage shrinks.

The first-RMD-year decision

The year you turn 73 (or 75 if born in 1960 or later), you have a one-time option: defer your first RMD until April 1 of the following year. But if you do, you'll take two RMDs in year two — which stacks income and may push you into a higher bracket or over an IRMAA threshold. For most retirees who are considering conversions, taking the first RMD in the calendar year they turn 73 is simpler and leaves more control over total income in year two.

The planning complexity post-73

Before 73, Roth conversion planning is relatively tractable: estimate your annual income from other sources, fill a bracket, and repeat. After 73, RMD income is mandatory and grows with the balance each year, SS is typically fully on, IRMAA is an active constraint, and the interaction between all three layers (bracket + SS torpedo + IRMAA) compresses the decision space significantly.

The right conversion amount in this environment is almost always computed by modeling all four income layers simultaneously — not just "how much bracket room do I have." A fee-only specialist runs this projection annually, adjusting for IRA balance changes, SS COLA increases, and bracket inflation.