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You’re asking about hypothetical penalties on a bill that hasn’t been passed on a hypothetical timeline that hasn’t happened. No one knows.
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PC1 has it right but the problem is many of us need to decide by no later than next week if we want to do an after tax 401k contribution on our final 2021 paycheck. We won't be able to convert it to Roth until early Jan 2022 so it isn't obvious what we should do.
It doesn't seem like the Senate is going to look at this until the week of 12/13 which is too late for me to change contribution rate so I'll probably stop it early.
That said, while there is precedent to have income taxe rate changes be retroactive to beginning of the year it wouldn't seem fair to go back and penalize you for doing backdoor/mega backdoor in January if it was legal at the time.