Roth Conversion Window 2028
The sunsetting TCJA tax cuts make 2025–2028 a rare conversion window. Here's what pre-retirees need to know before rates reset.
The Roth conversion window refers to the likely expiration of TCJA provisions scheduled to sunset after December 31, 2025. If Congress does not act, the 22% and 24% brackets revert to 25% and 28%. For pre-retirees sitting on large traditional IRA or 401(k) balances, that rate difference is the window.
Why 2028 Shows Up in This Search
The true window is 2025 through 2028, not starting in 2028. Converting across multiple years lets you fill a bracket repeatedly without a single-year income spike that triggers other costs.
What the window represents is a pricing advantage. A $200,000 conversion at 22% costs $44,000 in federal tax. At 25%, that same conversion costs $50,000. The six-thousand-dollar gap is gone before the money grows a dollar.
Congress could extend the TCJA cuts, modify them, or replace them with something different. What is certain is that current rates are lower than their scheduled successors.
The Rules and Tradeoffs That Actually Decide This
IRMAA. Medicare premiums are based on your MAGI from two years prior. A large conversion in 2025 shows up in your 2027 premiums. The 2025 IRMAA surcharges begin at $106,000 for single filers and $212,000 for married filing jointly. A conversion that crosses those thresholds can partially offset the rate savings.
ACA premium subsidies. If you retire before Medicare eligibility and buy coverage on the exchange, conversions add to MAGI and can reduce or eliminate premium tax credits. Depending on your subsidy, a conversion could cost more than the bracket differential suggests.
The five-year rule. Each Roth conversion carries its own five-year seasoning clock for penalty-free withdrawal of converted principal. If you are under 59½, know which clock applies before you convert with near-term spending in mind.
State taxes. Federal brackets are only part of the bill. A 24% federal rate plus a 5% state rate is 29%, which changes the breakeven analysis materially.
A Worked Example (Illustrative)
I had a client (details changed) who retired at 62 with $1.4 million in a traditional IRA, Social Security deferred to 70, and no pension. His income from 62 to 70 was minimal, putting him in an unusually low bracket for those eight years.
We identified roughly $80,000 per year of conversion capacity within the 22% bracket, factoring in the standard deduction and a small amount of dividend income. Over six years he moved roughly $480,000 into Roth at current rates. He did not wait until 2028 to start.
How This Connects to the Roth Conversion Calculator and Bracket Guide
The bracket-by-bracket analysis, the IRMAA interaction by income level, and the year-by-year sequencing live in the parent pillar. The Roth Conversion Calculator and Bracket Guide is where you can stress-test your own numbers and work through the ACA and IRMAA watchouts specific to your income.
In the language of the Sporos Doctrine, this work sits in the Soil layer of the plan. Tax architecture is built before the tree grows, because a 7% return in the wrong wrapper is not a 7% return.
Frequently Asked Questions
Is the Roth conversion window really closing in 2028?
The TCJA provisions are scheduled to sunset after December 31, 2025, so lower rates are available now under current law. Whether Congress extends or allows the cuts to expire determines what rates look like from 2026 forward.
What happens to my Roth account if rates do not go up?
Your Roth balance still grows and distributes tax-free, and RMD obligations are removed. You lose the rate-arbitrage advantage, but the conversion is not a loss.
Can I convert just part of my IRA?
Yes. Partial conversions are common and often preferable, letting you fill a specific bracket each year without triggering IRMAA surcharges or pushing into a higher tier.
Does a Roth conversion count as income for Social Security taxation?
Yes. Converted amounts increase your combined income and can push up to 85% of your Social Security benefit into the taxable range, making sequencing relative to your Social Security start date particularly important.
What to Do Next
Two facts change this analysis more than anything else: your current effective rate versus your expected rate in retirement, and your exposure to IRMAA or ACA subsidy cliffs. If those work in your favor, converting now has a real case. If one cuts against you, the window is smaller than the headline suggests.
Where this goes wrong most often is not in the conversion itself but in the single-year spike. People convert a large amount and inadvertently cross an IRMAA tier, lose a subsidy, or trigger the net investment income surtax. They did the math on the bracket. They did not model the full income picture for that year.
This is worth a real conversation if you have more than $500,000 in pre-tax accounts, are within five years of retirement or already in an income-gap year, and have not mapped the next three years of bracket exposure against your conversion capacity. If that describes you, schedule a call to talk through whether the fit is right.
The information provided is for educational purposes only and does not constitute investment, legal, or tax advice. Tax law changes frequently — verify current rules before acting. Consult with qualified professionals for guidance specific to your situation.
More in this guide
- › Roth Conversion After Retirement
- › Roth Conversion Calculator
- › Roth Conversion Ladder: How Early Retirees Bridge to 59½
- › Roth Conversion Strategies For 65 Retired Person
Related reading
This is one piece of a bigger picture. For the full strategy, see our pillar guide:
Roth Conversion Calculator and Bracket Guide →Or see how we handle this for clients:
Tax Optimization →The information provided is for educational purposes only and does not constitute investment, legal, or tax advice. All investing involves risk, including the potential loss of principal. Consult with a qualified financial professional before making any financial decisions. Securities and advisory services offered through LPL Financial, a Registered Investment Advisor. Member FINRA & SIPC.
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