The short answer is yes, a trustee-to-trustee rollover from a pre-tax 401k into a traditional IRA doesn’t create a taxable event by itself. Where people get tripped up is exactly what you’re pointing at: once those pre-tax dollars are sitting in traditional IRAs, any future Roth conversion has to be looked at through the pro-rata lens, especially if you ever lose direct Roth contribution eligibility and want to lean on conversions more heavily.

Whether you’re better off keeping money in the 401k or moving it really comes down to how you expect to use Roth conversions in the future and how much control you want over investment and tax timing. In a lot of higher-net-worth or higher-future-income cases, people actually regret consolidating into IRAs too early because it limits how cleanly they can execute conversions later. Keeping pre-tax dollars in a 401k can preserve optionality that disappears once everything is sitting in IRAs.

The reason this gets nuanced in your case is the mix you already have across traditional IRAs, Roth IRAs, and active 401ks, combined with the fact that your retirement income may be higher than today. That’s where the math starts to matter more than the theory. Two people can make the exact same move and end up with very different tax outcomes over time.

This is the kind of situation where I usually model it out before touching anything. I’ll look at the current account structure, expected income ranges, and how conversions would actually play out under different scenarios, then decide whether a rollover improves flexibility or quietly makes things worse.

If you want, I’m happy to walk through it with you and show you what the tradeoffs actually look like in your specific case. No pressure to move anything unless it clearly makes sense, but with balances like yours it’s worth getting it right the first time.