Emphasis added.
I think whether the tax paid is "early" can be a matter of how one does the accounting and perspective. (Note that I know just enough about accounting to be dangerous.)
One pays the tax when the withdrawal (or conversion) is made, no earlier and no later, so in that sense it is always paid "on time". The breakeven thought seems to rely on the premise that if the withdrawal (or conversion) was not made at the time, that it would have been made later.
One could easily and I think just as accurately say that the tax would have been made earlier (at the time of deferral aka contribution to the IRA or workplace plan). In this view, the payback is immediate, because the person would have otherwise paid taxes at 22% or more when the contribution was made, and paying it at 12% later completes things.
The risk to the "breakeven" point of view and logic is that it's not really known when that dollar that was withdrawn or converted would have ultimately been taxed later. (This comes up in "whether to convert" discussions all the time.) The laws might change. Rates might change. The IRA dollars might end up going to charity and essentially come out tax free.
From an accounting point of view, I think it depends on whether one puts on their balance sheet anything to account for the embedded tax liability associated with the IRA dollars. Most people (including me) think and act on a cash, not accrual basis, so we don't formally account for that embedded liability.