Regardless of income but subject to contribution limits, contributions can be made to a Traditional IRA and then converted to a Roth IRA.[23] This allows for “backdoor” contributions where individuals are able to make Roth IRA contributions even if their income is above the limits.
Also income limits on a Roth IRA are easy to circumvent with the back door workaround.
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From Wikipedia:
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Then one needs the Mega Backdoor ROTH