Thank you. I will assume you are correct, but without digging too deeply: The first reference to 408A(d)(3) that defines a Roth rollover as a taxable conversion is irrelevant, as taxes are due on all Roth conversions from a traditional IRA, whether as a result of an RMD or for any other reason. That would include funds rolled over that originated as an RMD. Section 403A(d)(3)(E) refers to "Special rules for contributions to which 2-year averaging applies." It does not expressly reference RMDs at all, and insofar as I am aware, RMDs are not "contributions to which two year averaging applies". Perhaps you intended to refer to a different statute.
