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How Roth Conversions Affect NIIT

NIIT is the Net Investment Income Tax. A Roth conversion is not itself net investment income, but it can raise MAGI enough to expose investment income to the additional 3.8% tax.

3.8%Net Investment Income Tax rate
$200kSingle / head of household MAGI threshold
$250kMarried filing jointly MAGI threshold

The Rule

NIIT applies to the lesser amount

The 3.8% NIIT generally applies to the lesser of net investment income or the amount by which modified adjusted gross income exceeds the applicable threshold.

Filing statusMAGI thresholdNIIT base
Single / Head of household$200,000Lesser of net investment income or MAGI above threshold
Married filing jointly$250,000Lesser of net investment income or MAGI above threshold
Married filing separately$125,000Lesser of net investment income or MAGI above threshold

Why Roth Conversions Matter

The conversion can unlock tax on existing investment income

Because a Roth conversion increases MAGI, it can cause dividends, interest, capital gains, rental income, or other investment income to become subject to NIIT. The conversion itself is ordinary income, but it may be the income that pushes the household above the NIIT threshold.

The planning opportunity: test conversion size against taxable-account income and decide whether to harvest gains, defer gains, use charitable strategies, or convert in years when investment income is lower.

Example

$90,000 conversion near the NIIT threshold

Assume a married couple has $235,000 MAGI and $70,000 of net investment income. Before the conversion, only $0 to $55,000 may be near the threshold depending on the exact MAGI calculation. Add a $90,000 conversion, and MAGI rises to $325,000. NIIT applies to the lesser of $70,000 of net investment income or $75,000 over the $250,000 threshold, so $70,000 could be exposed to the 3.8% tax.

Sources

Reference material