SEPP Scenarios Requesting Assistance
Background info for SEPP Questions:
DOB is Feb 20 1964 so turned 55 1/2 on Aug 20 2019 and plan to take first year full amount distribution on Sept 17 2019.
Plan to separate 401K IRAs from several different employers so that 700K is in the SEPP pool and 70K is outside of the SEPP based on Dec 31 2018 values in accounts.
Plan on using the RMD Method with the Uniform Life Table and will use the EXACT amounts in my accounts on Dec 31 of the previous year for calculations.
Have emergency funds (ROTH IRA contributions, stocks) available to tap without penalty and avoid busting the 72t before the 5 years are up on Sep 17 2024 as I realize using the RMD method results in lower annual payouts.
(1) Can I separate my 401K IRAs and leave the 70K outside of the SEPP pool so that I can dip into it without restrictions once I turn 59 1/2 on Aug 20 2023?
(2) The first year calculation using the Uniform Table for age 55 appears to be $700,000 / 41.6 (age 55 number) so my SEPP distribution for this year 2019 is 16,826.92, correct?
(3) If my math is right in #2 above, then I would divide the amount in my accounts as of Dec 31 the previous year for 5 years until I reach 59.5 so 2019, 2020, 2021, 2022, and 2023. The Uniform Life Table shows 41.6, 40.7, 39.7, 38.7, and 37.8 for ages 55 – 59. Is this all accurate?
(4) Am I able to take the payments at any time during the year? For example, I plan to take first payment in about 2 weeks on Sep 17, 2019. Can I take my 2020 payment for year 2 at anytime during the year say in Jan 2020 or May 2020 or do I have to wait until a full year goes by so forced to take the full payment after Sep 17 2020? Does same timing of payment rule apply for all following years including the final year in 2023 when I turn 59 1/2?
(5) After I take the 5th and final payment sometime in 2023, then I cannot take any more 72t distributions from the SEPP until AFTER Sep 17 2024 so that I complete the full 5 year anniversary cycle, correct? If so, after Sep 17, 2024 I can take out any money I want from my SEPP 401K IRA accounts with no 10% early withdrawal penalty as the SEPP 5 year / 59.5 age rules will be satisfied, correct?
(6) I plan on withdrawing all payments from one 401K IRA with about $150K in it right now. If it somehow goes to $0 before the 5 years of SEPP distributions are up, can I take money out of another IRA that is part of the SEPP pool?
(7) Will the IRS be concerned that I will need to recalculate distribution amount every year due to RMD method via Uniform Life Table and make it more likely for me to be audited? Is there a way to indicate method used on IRS tax form?
(8) Will the holder (aka Vanguard, Fidelity, etc.) of my 401K IRA be able to indicate on the tax documentation they send me that my distributions are from using SEPP and do not incur the 10% penalty? If not, is it form 5392 that I have to file if broker will not mark payment as SEPP? What percentage of taxes (20%?) are withheld from SEPP payments?
(9) Finally, are there any “gotchas” that people seem to overlook when setting up their SEPP that causes them to be hit by the 10% early withdrawal penalty and interest charges by the IRS?
I apologize for the lengthy set of questions but I want to avoid making any costly errors. THANKS again for all of your assistance…much appreciated!!
Permalink Submitted by Alan - IRA critic on Wed, 2019-09-04 04:32
Permalink Submitted by Carolina Williams on Wed, 2019-09-04 13:51
Alan, you have convinced me to use the Fixed Amortization Method as I can use a lower 401K balance to generate the same annual distribution that I need for living expenses.
Alan, thanks again for all of your help!
Permalink Submitted by Carolina Williams on Wed, 2019-09-04 14:21
Alan, I have NOT rolled over my 401K accounts. I have 4 accounts from different employers with Fidelity and 1 account with Vanguard. Based on your analysis and suggestion about using fixed amortization method, I now want to use only two 401K accounts from Fidelity totalling about 485K to fund my SEPP but it sounds like you are suggesting combining these two 401K accounts into one IRA account to fund the 72t plan. Please see next comment below for questions about fixed amoritization method and how to proceed.
Permalink Submitted by Alan - IRA critic on Wed, 2019-09-04 16:08
Permalink Submitted by Carolina Williams on Wed, 2019-09-04 18:20
Alan, you have convinced me that it is safest to take the Fidelity 401K plans and put them into a Rollover IRA with Fidelity. One of my four 401Ks worth about 185K has company stock so I decided not to use it in the rollover and instead use the three other 401Ks that will still get me roughly the 485K that I need to fund the 72t plan. NONE of the 401ks is a Roth IRA. Here are my next steps:
Alan, how long do you think it will take for Fidelity to establish the rollover IRA and move the funds completely from the three 401Ks? Any chance they can do it by the end of Sept so that I can get distribution by Sep 30 and get to use the much higher July interest rate? Since the rollover IRA and the 401ks are all with Fidelity, I am hopeful it can be completed in a couple of weeks. Thoughts?
Permalink Submitted by Alan - IRA critic on Wed, 2019-09-04 20:09
Unless there is some complication in the rollover process, you should be able to complete the direct rollovers to a single IRA account and take your first 72t distribution by the end of Sept. Once all the accounts have been consolidated in the rollover IRA, you should make a copy of your on line account showing the balance and keep that copy along with the calculations for your plan. This should be a simple plan setup that should not be confusing to the IRS as there will be only one 1099R issued for the same amount each year.
Permalink Submitted by Carolina Williams on Thu, 2019-09-05 16:07
Alan – I setup the rollover IRA account with Fidelity and the money from my 401ks will be moved after close of trading today. Thanks for all of your assistance…much appreciated!!
Permalink Submitted by Carolina Williams on Mon, 2019-09-09 18:46
Alan, please confirm my 72t calculation is correct.
Does this sound correcct? I plan to take this year (2019) as one-time payment of $23,449.61.
Permalink Submitted by Alan - IRA critic on Mon, 2019-09-09 23:39
Your figures are correct, but the Fidelity calculator rounded the annual to 23,450 even. You can use your rounded monthly figures, and on your 1040 line 4 you will show 23,450 for both 2019 and later years when you take the rounded monthly amounts. I have not heard of the IRS requiring pin point rounding or busting any plans for minor differences in rounding. However, in 2020 when you set up monthly installments, try to get the payout date between the 5th and 20th of each month. Avoid the first few days or the last few days of the month to avoid issues with the Dec distribution being missed or the Jan. distribution being made too early.
Permalink Submitted by Carolina Williams on Tue, 2019-09-10 00:56
I am tempted to just get the payments on a one-time annual basis for 2020 – 2023 and eliminate the chances of an error in distributing the monthly payments (missed Dec / early Jan) by Fidelity.
Permalink Submitted by Alan - IRA critic on Tue, 2019-09-10 01:25
Permalink Submitted by Carolina Williams on Wed, 2019-12-04 19:47
2019 Rollover IRA and 1099R Form Info for Distribution Alan – please start at CONFIRMATION 72T CALCULATION entry for detailed info for this question. I rolled over three 401Ks to a Rollover IRA (all accounts with Fidelity) which was completed on Sept 5 2019. All money total of $486,368.57 was moved internally by Fidelity and never touched my hands. I then took 72T distribution on Sep 11 2019 of $23450.
Alan, thanks again for all of your help…much appreciated!
Permalink Submitted by Alan - IRA critic on Thu, 2019-12-05 01:26
Permalink Submitted by Carolina Williams on Thu, 2019-12-05 03:29
I just checked the IRS website for 1040 and 5329 forms for tax year 2019 and the associated instructions. Let me make sure that I am understanding this correctly based on your response above:
Alan, does this all seem accurate? I apologize if this info seems basic but I want to ensure that I fill out the tax forms correctly for 2019 as it will set me up for success in the following years. Of course, there will be no rollover of 401ks in future years so in 2020 – 2023, Lines 4c and 4d will be left blank. Thank you!
Permalink Submitted by Alan - IRA critic on Thu, 2019-12-05 03:40
Yes, you are entirely correct. If you file with a tax program, the forms generated should follow the above, but it is good to know what they should look like if you plan to use a tax program – or even if you use a fee preparer because they do not always get this right.
Permalink Submitted by Alan - IRA critic on Wed, 2020-01-01 21:08
There has been no indication that the IRS is concerned with rounding conventions. Remember, the “S” in SEPP stands for “substantially”. If set up monthly or other automatic distributions to be equal, you will have to round them to the nearest penny, so you will always be a few cents over or under your indicated annual amount. As for the initial balance, enter the exact balance that you can document with a statement copy or screen print, but if the calculator you use rounds to the nearest dollar, don’t worry about the cents. You will find that some calculators make different assumptions about how often during the year you plan to take distributions. If you run into one of those, just elect annual payment. You are free to take your distribution in whatever pattern you wish. The only thing that matters is what the 1099R adds up to for all distributions during the year.
Permalink Submitted by Bruce Capasso on Thu, 2020-01-02 17:54
Thank you Alan. Bruce.
Permalink Submitted by Bruce Capasso on Thu, 2020-01-02 17:46
Hello, I was wondering if you could answer a few question regarding calculation on the IRA balance and the distribution being to the penny. I am 54 with a 12/25/1965 birthday. Lets say the day I select for the SEPP 72t balance is 1/15/2020 and the IRA balance is $401,225.27. Using the single amortized method, do I round that to $401,225 for the calculated balance? Also, many online SEPP 72t calculators round the balance and distribution however I’ve read it has to be to the exact penny. Is there and accurate to the penny calculator you can recommend? Thank You, Bruce Capasso.