Yes, the RMD at age 70 on a $10M tax-deferred account is about $360K. Not enough to get a married couple into the highest bracket by itself. But my point is a $2M or $3M or $5M tax-deferred account is hardly an RMD problem.
The point I was making is that you can potentially save significant amount in taxes by doing the Roth conversion vs. not doing it, but many factors will affect whether this is a strategy worth taking, and that it does not take $10M for the Roth conversion to make sense (at that point, the savings would be substantial), and someone with as little as $2M can benefit. I prefer to trust my own calculations (I actually assumed that in retirement the tax rate would not be very high), so unless someone can produce a comprehensive model that shows that Roth conversions are not recommended for the same set of assumptions, I believe that my answer is correct given the conservative assumptions I’m making. One factor that significantly affects the outcome is longevity, so the longer one is around, the more sense this strategy makes. I’ll definitely try to publish an article on this topic with the assumptions and calculations one of these days.
Oh, I agree you don't need an IRA anywhere near $2M to have a Roth conversion make sense. I was reading the OP's question as if it was possible to have a "too big" IRA, and I think probably not within the range that docs can realistically get to.
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