On p 253 of the proposed Regs, it now states that RMDs for all your IRAs must be completed before you convert from any of them. In the past, the IRS Regs allowed a taxpayer to complete the RMD for a particular account only, then convert additional amounts from that particular account before completing the RMD for other IRA accounts. This option will be gone unless the IRS does not adopt this provision when the final Secure Act Regs are published.
The exact provision follows:
(
3) Determination of portion of distribution that is a required minimum
distribution.
The portion of a distribution from an IRA that is a required minimum
distribution and thus not eligible for rollover is determined in the same manner as
provided in §§1.402(c)-2(f) and (j)(3) for a distribution from a qualified plan. For
example, if a minimum distribution to an IRA owner is required under section
401(a)(9)(A)(ii) for a calendar year, any amount distributed during a calendar
year from an IRA of that IRA owner is treated as a required minimum distribution
under section 401(a)(9) to the extent that the total required minimum distribution
for the year under section 401(a)(9) from all of that IRA owner’s IRAs has not
been satisfied (either by a distribution from the IRA or, as permitted under
paragraph (e) of this section, from another IRA).