The idea: we can collect the same amountof revenue without creating perverse economic incentives, including the incentive to avoid realizing taxableincome.
This rule can apply where there is a relatively greater amountof indebtedness in the U.S. than offshore, and net interest expense exceeds a specified percentage of adjusted taxableincome.
But the exact amount depends on your annual taxableincome, age, value of your IRA and how much it appreciates after conversion but before you have to make a decision on how much to keep as a Roth conversion.
In a progressive tax system, that also means that theamountof tax payable will be smaller since tax rates tend to decrease with taxableincome (with some exceptions, of course).