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In-plan conversion vs in-service distribution

The two conversion mechanics, their tax treatment, basis tracking, and how the Form 8606 reconciliation differs.

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01 / SPD decoder3-input decision tree

Does your plan permit the Mega Backdoor Roth?

Three questions about your Summary Plan Description. The same three answers always produce the same verdict — deterministic and statute-cited. Nothing is logged.

Q1Does your plan permit AFTER-TAX (non-Roth) employee contributions up to the §415(c) limit?
Q2Does your plan permit IN-PLAN ROTH CONVERSION of those after-tax contributions?
Q3If there is no in-plan conversion, does your plan permit IN-SERVICE DISTRIBUTION to a Roth IRA?

Awaiting inputs — answer Q1 to compute the verdict

Independent CPA / CFP review in progress

Both paths move after-tax 401(k) dollars into Roth. They differ in where the Roth money lands, how the earnings are taxed, and which tax forms you reconcile at filing time.

The comparison

DimensionIn-plan conversionIn-service distribution
Roth lands inThe 401(k)'s Roth accountAn external Roth IRA
Earnings before conversionTaxable as ordinary income at conversionTaxable as ordinary income at distribution
Form 8606Generally not required for the in-plan rollover itselfTracks after-tax basis rolled to the Roth IRA
Tax forms received1099-R (in-plan rollover, often code G)1099-R (distribution) + 5498 (Roth IRA rollover-in)
Roth IRA flexibilitySubject to plan rules and investment menuFull Roth IRA investment choice and access rules
Usual preferencePreferred, especially if automatic per pay periodGood substitute when in-plan conversion is unavailable

Why automation matters either way

The amount of taxable earnings depends on how long after-tax dollars sit before they are converted. A plan that converts automatically every pay period keeps the taxable sliver near zero. A plan that requires you to request conversions quarterly — or only allows annual in-service distributions — gives earnings more time to accrue, and those earnings are ordinary income when you convert. Frequency, not just permission, drives the tax outcome.

The basis-tracking difference

With the in-service-distribution path, you are moving after-tax basis out of the plan and into a Roth IRA, and Form 8606 is where that basis is reported. With the in-plan path, the conversion happens inside the plan and the recordkeeper handles the accounting; you generally do not file Form 8606 for the in-plan rollover itself. See the Form 8606 walkthrough and the 1099-R / 5498 reconciliation for the line-level detail.

Independent CPA / CFP review in progressLast verified 2026-06-16

Informational, not tax advice. Consult a CFP, CPA, or Enrolled Agent before acting on any Mega Backdoor Roth conversion. Plan rules are plan-document-specific — verify with your benefits administrator. IRS dollar limits change annually.