72t. Rollover

Client started 72t in 2020 with IRA at Merrill. Wants to transfer her entire IRA. As long as all assets move, are there any penalties?

Client owns all mutual funds, stocks, and etfs. Client would liquidate any assets that would not be accepted by TD Ameritrade, then moved.

IRA would be transferred from Merrill to IRA at TD Ameritrade.



DIrect transfer of an entire 72t plan IRA is allowed, but in the past a few partial transfers became problems. For this client, they need to carefully coordinate the transfer year distributions to make sure that the 1099R totals exactly equal the 72t calculation. Form 5329 will certainly need to be filed to report the 72t penalty exception code 02. Otherwise, there should be no problem.

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