The IRS does lump all Roth IRAs together and treat them as a single account for the purpose of withdrawal ordering rules. You cannot choose to withdraw only from a specific account; all your Roth IRAs are aggregated.
The IRS mandates a specific order in which funds are considered to be withdrawn, which applies across all your Roth IRA accounts:
- Direct Contributions: Your own direct contributions to any Roth IRA are always considered to come out first. These can be withdrawn at any time, tax-free and penalty-free.
- Conversions and Rollovers: Next come amounts from conversions and rollovers (such as from a traditional 401(k) or IRA). These are tracked as separate "pots" or layers, each potentially subject to its own 5-year clock for penalty-free withdrawal of the principal amount.
- Earnings: Finally, earnings on all contributions and conversions are considered to be withdrawn. Earnings are tax-free and penalty-free only if the distribution is a "qualified distribution" (generally after age 59½ and after the main 5-year earnings-tracking rule is met).
Even if you maintain separate physical accounts to simplify record-keeping for your own tracking purposes (which is a common strategy), the IRS views the money across all accounts as one pool and the mandated withdrawal order must be followed for tax reporting.
