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Ordering Rules for Distributions: IRA Withdrawals (2025 IRS Guide)

This guide covers “Ordering Rules for Distributions” within ira withdrawals. The following material presents the IRS treatment of this topic, including the qualifications, exceptions, and examples in the source section. Read the rules alongside the facts of your own situation before deciding what to report, deduct, or document.

Adapted from Publication 590-B (2025), Distributions from Individual Retirement Arrangements (IRAs), published by the Internal Revenue Service. This guide retains the source edition’s years, amounts, deadlines, and examples. It is guidance for that edition, not a statement that the same figures apply to every tax year.

Context for these rules

You don't include in your gross income qualified distributions or distributions that are a return of your regular contributions from your Roth IRA(s). You also don't include distributions from your Roth IRA that you roll over tax free into another Roth IRA. You may have to include part of other distributions in your income. See Ordering Rules for Distributions, later.

Ordering Rules for Distributions

If you receive a distribution from your Roth IRA that isn't a qualified distribution, part of it may be taxable. There is a set order in which contributions (including conversion contributions and rollover contributions from qualified retirement plans) and earnings are considered to be distributed from your Roth IRA. For these purposes, disregard the withdrawal of excess contributions and the earnings on them (discussed under What if You Contribute Too Much? in chapter 2 of Pub. 590-A). Order the distributions as follows.

Regular contributions.
Conversion and rollover contributions, on a first-in, first-out basis (generally, total conversions and rollovers from the earliest year first). See Aggregation (grouping and adding) rules, later. Take these conversion and rollover contributions into account as follows.
1. Taxable portion (the amount required to be included in gross income because of the conversion or rollover) first.
2. Nontaxable portion.
Earnings on contributions.

Disregard rollover contributions from other Roth IRAs for this purpose.

Aggregation (grouping and adding) rules.

Determine the taxable amounts distributed (withdrawn) by grouping and adding together distributions and contributions as follows.

Add together all distributions from all your Roth IRAs during the year.
Add together all regular contributions made for the year (including contributions made after the close of the year, but before the due date of your return). Add this total to the total undistributed regular contributions made in prior years.
Add together all conversion and rollover contributions made during the year. For purposes of the ordering rules, in the case of any conversion or rollover in which the conversion or rollover distribution is made in 2025 and the conversion or rollover contribution is made in 2026, treat the conversion or rollover contribution as contributed before any other conversion or rollover contributions made in 2026.

Add any recharacterized contributions that end up in a Roth IRA to the appropriate contribution group for the year that the original contribution would have been taken into account if it had been made directly to the Roth IRA.

Disregard any recharacterized contribution that ends up in an IRA other than a Roth IRA for the purpose of grouping (aggregating) both contributions and distributions. Also, disregard any amount withdrawn to correct an excess contribution (including the earnings withdrawn) for this purpose.

Example.

On October 15, 2021, Amelia converted all $80,000 in her traditional IRA to her Roth IRA. Her Forms 8606 from prior years show that $20,000 of the amount converted is her basis.

Amelia included $60,000 ($80,000 − $20,000) in her gross income.

On February 23, 2025, Amelia made a regular contribution of $5,000 to a Roth IRA. On November 8, 2025, at age 60, Amelia took a $7,000 distribution from her Roth IRA.

The first $5,000 of the distribution is a return of Amelia's regular contribution and isn't includible in her income.

The next $2,000 of the distribution isn't includible in income because it was included previously.

Figuring your recapture amount.

If you had an early distribution from your Roth IRAs in 2025, you must allocate the early distribution by using the Recapture Amount—Allocation Chart located in Appendix C.

Amount to include on Form 5329, line 1.

Include on line 1 of your 2025 Form 5329 the following four amounts from the Recapture Amount—Allocation Chart that you filled out.

The amount you allocated to line 20 of your 2025 Form 8606.
The amount(s) allocated to your 2015 through 2025 Forms 8606, line 18.
The amount(s) allocated to your 2020 through 2025 Forms 1040, 1040-SR or 1040-NR, line 5b; 2019 Form 1040 or 1040-SR, line 4d; 2018 Form 1040, line 4b; your 2016 and 2017 Forms 1040, line 16b; Forms 1040A, line 12b; or 2015 through 2019 Forms 1040-NR, line 17b.
The amount from your 2025 Form 8606, line 25c.

Also, include any amount you allocated to line 20 of your 2025 Form 8606 on your 2025 Form 5329, line 2, and enter exception number 09.

Illustrated Recapture Amount—Allocation Chart

Enter the amount from your 2025 Form 8606, line 19		$85,500
Before you begin: You will need your prior year Form(s) 8606 and income tax return(s) if you entered an amount on any line(s) as indicated below. You will now allocate the amount you entered above (2025 Form 8606, line 19) in the order shown, to the amounts on the lines listed below (to the extent a prior year distribution wasn't allocable to the amount). The maximum amount you can enter on each line below is the amount entered on the referenced lines of the form for that year. Note. Once you have allocated the full amount from your 2025 Form 8606, line 19, STOP. See Ishmael’s Example above.
Tax Year	Your Form
2025	Form 8606, line 20	$10,000	Form 8606, line 22	$55,500
2005	Form 8606, line 18	$10,000	Form 8606, line 17	$-0-
2016	Form 8606, line 18; and Form 1040, line 16b; Form 1040A, line 12b; or Form 1040NR, line 17b*	$20,000	Form 8606, line 17; and Form 1040, line 16a; Form 1040A, line 12a; or Form 1040NR, line 17a**	$20,000
2025	Form 8606, line 25c	_____
* Only include those amounts rolled over to a Roth IRA. ** Only include any contributions (usually box 5 of Form 1099-R) that were taxable to you when made and rolled over to a Roth IRA.

Example.

Ishmael opened a Roth IRA in 2000 at age 32. He made the following transactions into his Roth IRA.

In 2005, he converted $10,000 from his traditional IRA into his Roth IRA. He filled out a 2005 Form 8606 and attached it to his 2005 Form 1040. He entered $0 on line 17 of Form 8606 because he took a deduction for all the contributions to the traditional IRA; therefore, he has no basis. He entered $10,000 on line 18 of Form 8606. He also entered zero on Form 1040, line 15a, and $10,000 on line 15b.
In 2016, he rolled over the balance of his qualified retirement plan, $20,000, into a Roth IRA when he changed jobs. He used a 2016 Form 1040 to file his taxes. He entered $20,000 on line 16a of Form 1040 because that was the amount reported in box 1 of his 2016 Form 1099-R. Box 5 of his 2016 Form 1099-R reported $0 because he didn't make any after-tax contributions to the qualified retirement plan. He entered $20,000 on line 16b of Form 1040 because that is the taxable amount that was rolled over in 2016.

The total balance in his Roth IRA as of January 1, 2025, was $105,000 ($50,000 in contributions from 2000 through 2024 + $10,000 from the 2005 conversion + $20,000 from the 2016 rollover + $25,000 from earnings). He hasn't taken any early distribution from his Roth IRA before 2025. In 2025, he made a contribution of $5,500 to his Roth IRA.

In August 2025 he took a $85,500 early distribution from his Roth IRA to use as a down payment on the purchase of his first home. See his filled out Illustrated Recapture Amount Allocation Chart to see how he allocated the amounts from the above transactions. Based on his allocation, he would enter $20,000 on his 2025 Form 5329, line 1 (see Amount to include on Form 5329, line 1, earlier). He should also report $10,000 on his 2025 Form 5329, line 2, and enter exception 09 because that amount isn't subject to the 10% additional tax on early distributions.

Using the guidance

Keep the documents that establish the dates, amounts, and circumstances described above. References to other chapters, forms, worksheets, or earlier and later sections refer to the linked IRS publication. Check the full publication and its updates before relying on a rule for a different tax year or a situation not addressed here.

Sources and further reading

Publication 590-B (2025), Distributions from Individual Retirement Arrangements (IRAs): Roth IRAs — Are Distributions Taxable? — Ordering Rules for Distributions — Internal Revenue Service; 2025 edition.

The cited U.S. government text is in the public domain. Source accessed October 28, 2026. Fynoptic has organized this material for educational use and is independent of, and not endorsed by, the IRS.

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