The post-OBBBA $15M permanent estate exemption changes the math on Roth conversions for high-net-worth clients. The traditional case for Roth conversion centered on (a) avoiding required minimum distributions for the original owner and (b) preserving tax-free growth for beneficiaries. With the SECURE Act's 10-year payout rule ³ for non-spouse beneficiaries (effective 2020+), the estate-planning case for Roth conversion grew dramatically. The post-OBBBA exemption increase adds a new dimension: for clients whose total wealth fits under the $30M MFJ exemption, the estate-tax-avoidance motive disappears, but the income-tax-bracket arbitrage remains.
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