Annuity Income and IRMAA: How Annuity Distributions Affect Medicare Premiums
Whether and how much an annuity distribution counts toward IRMAA depends on the type of annuity and how it was funded. A qualified annuity rollover pays full ordinary income on every distribution. A non-qualified deferred annuity has a trap: partial withdrawals are taxed as earnings first, not as basis — meaning the first dollars you take out are 100% taxable, even if most of your account is after-tax principal. A single partial withdrawal of $50,000 from a deferred annuity with $200,000 in accumulated gains can push a retiree with $90,000 in base income from zero IRMAA to $2,884/year in surcharges.
Which annuities count toward IRMAA MAGI
| Annuity type | Counts toward IRMAA MAGI? | Key rule |
|---|---|---|
| Qualified annuity (IRA annuity, 401k-funded, traditional pension annuity rollover) | Yes — 100% of every payment | Funded with pre-tax money; full distribution is ordinary income, reported on 1099-R box 2a = box 1. No exclusion ratio. |
| Non-qualified deferred annuity — partial withdrawal before annuitization | Yes — earnings portion only, but LIFO: earnings come out first | IRC § 72(e)(5): withdrawals treated as income first. If accumulated earnings ≥ withdrawal amount, 100% of withdrawal is taxable. 1099-R shows taxable amount in box 2a. |
| Non-qualified immediate annuity (SPIA) or annuitized deferred annuity | Yes — taxable portion only (exclusion ratio) | IRC § 72(b): exclusion ratio = investment in contract ÷ expected return. Each payment is partially taxable, partially return of basis. Once basis is fully recovered, 100% of subsequent payments are taxable. |
| Roth annuity (qualified Roth IRA annuity distribution) | No — not included in MAGI | Qualified Roth IRA distributions are excluded from gross income. Age 59½+ and 5-year rule must be satisfied. Not taxable → not in AGI → not in IRMAA MAGI.2 |
| Annuity death benefit / inherited annuity | Yes — taxable portion counts | Beneficiary inheriting a non-qualified annuity owes tax on gains. Lump-sum accelerates all gains into MAGI in one year; "stretch" payments spread gains across years. For qualified annuities, 100% of distributions count. |
The non-qualified LIFO trap: worked example
Patricia, 68, bought a non-qualified variable annuity 20 years ago for $150,000 (her "cost basis"). It has grown to $430,000. The accumulated earnings are $280,000. She decides to take a $60,000 partial withdrawal to fund home repairs.
| Line item | Amount |
|---|---|
| Annuity contract value | $430,000 |
| Cost basis (Patricia's after-tax investment) | $150,000 |
| Accumulated earnings (gain over basis) | $280,000 |
| Withdrawal amount | $60,000 |
| Taxable amount under LIFO (earnings first; $60K < $280K accumulated gains) | $60,000 |
| Return of basis received | $0 |
The full $60,000 is taxable — it all flows to IRMAA MAGI. Patricia had expected that ~35% of her withdrawal would be tax-free return of basis ("the gain is 65% of the account, so 65% should be taxable"). That's the common misconception. The LIFO rule means all $60,000 is earnings until she has exhausted all $280,000 of accumulated gains across multiple future withdrawals.
If Patricia's other retirement income (Social Security 85%, RMDs) was $80,000, adding $60,000 in annuity income brings her 2024 MAGI to $140,000 — crossing the $137,000 Tier 2 threshold. Her 2026 Medicare surcharges increase by $2,884/year. Over two years: $5,768 in additional premiums from a withdrawal she thought was largely tax-free.
SPIA exclusion ratio: the better scenario
Once a non-qualified deferred annuity is annuitized — converted into a stream of periodic payments — the LIFO rule no longer applies. The IRS switches to the exclusion ratio under IRC § 72(b):1
Exclusion ratio = investment in contract ÷ expected return from annuity
Each monthly payment is split: the exclusion percentage is return of basis (non-taxable), and the remainder is ordinary income (counts toward IRMAA MAGI). Once you have recovered your full basis across all payments, subsequent payments become 100% taxable.
Example: David, 70, annuitizes a $400,000 non-qualified contract (cost basis $200,000) into a single-life SPIA paying $2,100/month. Based on IRS actuarial tables, his expected return (life expectancy × annual payment) is $504,000.
- Exclusion ratio = $200,000 ÷ $504,000 = 39.7%
- Each $2,100 payment: $834 return of basis (non-taxable), $1,266 ordinary income (taxable → IRMAA MAGI)
- Annual taxable annuity income: $1,266 × 12 = $15,192
- Basis is fully recovered after ~20 years; after that, $2,100/month is 100% taxable
Compared to a partial withdrawal strategy, annuitization creates smaller, predictable IRMAA MAGI each year — making it easier to manage bracket exposure across the two-year look-back window.
How annuity income appears on your tax return
Annuity distributions are reported on Form 1099-R:
- Box 1 — Gross distribution (total amount received)
- Box 2a — Taxable amount (what flows into IRMAA MAGI)
- Box 7 — Distribution code (code 1: early, no exception; code 7: normal; code D: annuity; varies by type)
The Box 2a amount flows to Form 1040: IRA distributions on Line 4b, pension/annuity distributions on Line 5b. Both are included in AGI (Line 11). IRMAA MAGI adds tax-exempt interest (Form 1040 Line 2a) back on top. For most retirees: IRMAA MAGI ≈ AGI + municipal bond interest.
2026 IRMAA brackets (based on 2024 MAGI)
Because of the two-year look-back, annuity distributions taken in 2024 determine your 2026 Medicare Part B and Part D premiums.3
| 2024 MAGI — single | 2024 MAGI — married filing jointly | Added Part B + D per person/year |
|---|---|---|
| $109,000 or less | $218,000 or less | $0 |
| $109,001–$137,000 | $218,001–$274,000 | +$1,148/yr |
| $137,001–$171,000 | $274,001–$342,000 | +$2,884/yr |
| $171,001–$205,000 | $342,001–$410,000 | +$4,619/yr |
| $205,001–$500,000 | $410,001–$750,000 | +$6,354/yr |
| Above $500,000 | Above $750,000 | +$6,936/yr |
For married couples, both spouses pay surcharges based on the combined household MAGI. A $60,000 annuity distribution that moves a couple from $270,000 to $330,000 MAGI shifts both from Tier 1 to Tier 2 — costing $3,472/year combined, for two years. That's $6,944 in added Medicare costs for one year's annuity withdrawal decision.
Calculate your annuity IRMAA impact
Enter your base retirement income and the taxable portion of your annuity distribution. For non-qualified deferred annuities with accumulated earnings exceeding the planned withdrawal, enter the full withdrawal amount as taxable. For SPIAs or annuitized contracts, enter the annual taxable amount shown on your 1099-R box 2a.
Five strategies to reduce annuity IRMAA exposure
1. Spread large non-qualified withdrawals across multiple tax years
If you have a large accumulated-earnings balance in a deferred annuity, taking smaller partial withdrawals spread across 3–5 years keeps each year's taxable MAGI in a lower IRMAA tier. A single $150,000 withdrawal from a high-gain annuity may push you to Tier 4 ($4,619/year additional); three withdrawals of $50,000/year may keep you in Tier 1 or Tier 2. Because of the two-year look-back, you can plan annuity distributions now and know their IRMAA impact for years 2–3 ahead.
2. Annuitize to shift from LIFO to exclusion-ratio treatment
Once you annuitize, the LIFO rule no longer applies. Monthly annuity payments are taxed on an exclusion-ratio basis — a fixed percentage of each payment is return of basis (non-taxable). For high-gain non-qualified deferred annuities where most of the balance is earnings, annuitization can meaningfully reduce the taxable portion of each annual distribution, even if the total payments over time are the same.
Annuitization is generally irreversible. It's a one-time decision that also removes the flexibility to take larger withdrawals in low-income years. Modeling the exclusion ratio and comparing it against a spread-withdrawal strategy is worth doing before you commit.
3. 1035 exchange to shift gains into a Roth IRA (if eligible)
A non-qualified annuity can be exchanged for a Roth IRA under IRC § 1035 only if the annuity was held in a Roth IRA to begin with — direct 1035 exchanges from non-qualified annuities to Roth IRAs are not permitted. However, a 1035 exchange to a new non-qualified annuity, followed by partial withdrawals structured to stay below IRMAA cliffs, can be combined with Roth conversion planning in low-income years to gradually shift wealth out of the taxable annuity structure.4
4. Use QCDs to offset stacked MAGI from annuity + RMDs
If you are age 70½ or older, Qualified Charitable Distributions up to $111,000/person in 2026 remove IRA distributions from AGI entirely — they never appear on your return.5 If your annuity distribution will push you close to or over an IRMAA threshold, redirecting a portion of your IRA RMD as a QCD can create headroom. QCDs cannot offset non-IRA annuity income directly, but they reduce the total MAGI stack that the annuity income lands on top of.
5. Time large one-time withdrawals to low-income years
Partial lump-sum withdrawals from deferred annuities are best taken in years when other income is temporarily low: after retirement (before RMDs begin), in a year with large deductions, or in a year when capital gains were light. The worst year for a large annuity withdrawal is one where you also have a large RMD, a capital gain from a home sale, or a Roth conversion. Each dollar of annuity income stacks on top of other income — one more tier crossing costs $1,735/year per person minimum.
What about SSA-44?
The SSA-44 life-changing event appeal allows you to use current-year income instead of the two-year-old MAGI in limited circumstances: retirement, divorce, death of spouse, cessation or reduction of income-producing property. A voluntary annuity withdrawal is not a qualifying event. If high IRMAA from an annuity withdrawal is baked into your 2024 return, you will pay the 2026 surcharges regardless — SSA-44 is not a remedy here.6
Related guides
- What counts as IRMAA MAGI — every income source and whether it counts
- RMDs and Medicare premiums — how required distributions interact with annuity income
- Capital gains and IRMAA — the same stacking problem with investment sales
- Rental income and IRMAA — Schedule E income and property sale spikes
- 7 strategies to reduce IRMAA surcharges — QCDs, Roth timing, income spreading
- How to appeal IRMAA (SSA-44) — when life-changing events let you use current-year income
- Roth conversions and IRMAA — how to convert before annuity distributions drive up MAGI
Model your annuity withdrawal timing with a specialist
Annuity IRMAA planning is one of the most underestimated retirement income problems — many retirees don't discover the LIFO rule until they receive a 1099-R showing 100% taxable income on a distribution they believed was partially return of basis. A fee-only advisor who specializes in Medicare-aware retirement income planning can model your annuity's accumulated earnings, map out a multi-year withdrawal schedule that keeps MAGI below IRMAA cliffs, and coordinate your annuity strategy with Roth conversions, RMDs, and QCDs.
Sources
- IRS Publication 575: Pension and Annuity Income. IRC § 72(e)(5): partial withdrawals from non-qualified deferred annuities are treated as income first (LIFO); cost basis is only recovered after all accumulated earnings are distributed. IRC § 72(b): exclusion ratio applies once an annuity is annuitized, dividing each payment between taxable income and non-taxable return of investment. Verified May 2026.
- IRS Publication 590-B: Distributions from Individual Retirement Arrangements (IRAs). Qualified Roth IRA distributions (age 59½+, 5-year rule met) are excluded from gross income under IRC § 408A(d)(1). Not included in AGI → not included in IRMAA MAGI. Verified May 2026.
- CMS: 2026 Medicare Parts A & B Premiums and Deductibles (November 2025). IRMAA single thresholds: $109K / $137K / $171K / $205K / $500K. MFJ: $218K / $274K / $342K / $410K / $750K. Combined Part B + D annual surcharges per person: $1,148 / $2,884 / $4,619 / $6,354 / $6,936. 2026 IRMAA is based on 2024 MAGI (two-year look-back). Verified May 2026.
- IRS Publication 575. IRC § 1035 exchanges: non-qualified annuity to non-qualified annuity is a tax-free exchange. Direct 1035 exchanges from non-qualified annuities to Roth IRAs are not permitted under current law. Roth IRA contributions remain subject to annual limits and income phase-outs; annuity proceeds may only fund a Roth IRA if withdrawn first (triggering taxable income under LIFO rules) and then contributed within Roth contribution limits.
- IRS Notice 2025-67: 2026 Retirement Plan Amounts — QCD limit $111,000 per person per year for taxpayers age 70½+, indexed per SECURE 2.0 § 307. QCDs satisfy RMD requirements and exclude distributed amounts from AGI entirely — taxable annuity income from a non-IRA source is not offset by QCDs directly, but QCDs reduce the AGI base on which annuity income stacks.
- SSA Form SSA-44 and Instructions. Seven qualifying life-changing events for IRMAA appeal: marriage, divorce/annulment, death of spouse, work stoppage, work reduction, loss of income-producing property (involuntary), reduction of income-producing property income. Voluntary annuity withdrawals are not qualifying events; the IRMAA determination based on a prior-year annuity distribution cannot be appealed via SSA-44.
IRMAA brackets reflect 2026 rules per CMS November 2025 announcement. Annuity tax treatment per IRS Publication 575, IRC § 72. Values verified May 2026. Consult a licensed advisor for guidance specific to your situation.
MedicareAdvisorMatch is a referral service, not a licensed advisory firm. We may receive compensation from professionals in our network.
Content is for informational purposes only and does not constitute financial, tax, legal, or investment advice.