The framing you laid out is basically right, and most people skip past it too fast. Ordinary income in, ordinary income out. The wrapper does not launder the character, it just moves the timing. Where it starts to pencil on the note side is a high-yield fund running 10 to 11% on performing seconds or bridge paper with everything reinvested. The compounding on the deferred portion is real over a 15 to 20 year horizon even when the exit rate matches the entry rate. Run a rough comparison on $150k at 10% compounding with no shelter against the same thing inside a traditional IRA at a 37% bracket going in and a projected 24% bracket in retirement. The gap comes out meaningful, somewhere around $60k over 18 years, purely from the deferral and the assumed rate drop at distribution. Not life-changing, and not nothing either. The thing to nail down before moving anything is what your realistic bracket looks like at distribution age, well beyond today's bracket. If you have other income sources in retirement, Social Security, a pension, other IRA RMDs, you may not drop as far as you are hoping, which compresses that gap fast. The Roth question is worth reframing slightly. Instead of converting now, look at whether you can direct new contributions or a small rollover into a Roth SDIRA and let the note income compound tax free from a lower basis, leaving the big existing chunk unconverted at 37%. The conversion hit is what kills it at your bracket, and accumulating fresh dollars in a Roth while the existing fund stays where it is might thread the needle better.