Net Un-realized Appreciation
I made a small trustee-to-trustee transfer from my 401k to IRA in December 2104. Did this action forever take away my NUA option when I am ready to do final lump sum 401k distribution?
If so, would any of following actions work for me:-
-Transfer back entire IRA account to 401k (IRA account made no trade, contains company stock and cash, it has since earned some interest and cash dividend)
-Go back to work for the same company again (any time limit I must return since that December transaction?)
-Death (would my spouse or non-spouse have NUA then?)
Any other ways that would work?
Any prior Private Letter Rulings (PLR) that are on my side? Should I look into my own PLR as this is a low 5-figure tax difference?
Permalink Submitted by Alan - IRA critic on Mon, 2015-05-25 21:42
Of your 3 ideas, only a return to work would create a new triggering event for you, which would be the second separation from service. If you have not reached 59.5 yet, that would also be a new triggering event that would erase the affect of your prior intervening distribution. If neither of these will work for you, it would likely be a waste of time and money to request a letter ruling, as it would cost you 10k plus legal costs to pursue a low probability ruling.