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Can an account balance dated before a (non-SEPP) withdrawal still be used to establish a SEPP?
Example with made-up numbers for clarity:
1/3/22: IRA account balance = $1,000,000.
1/23/22: Transfer $100,000 to a different IRA, leaving $900,000.
Is there anything preventing the 1/3/22 balance of $1,000,000 from being used for SEPP planning purposes even though there is only $900,000 of that left in the account? Is there specific language from the IRS addressing this?
That makes sense. However, there is nothing stopping you from including BOTH IRA accounts in your SEPP 72-T UNIVERSE. So, in your example, you can still use $ 1,000,000 if you include BOTH IRA accounts in your calculation. You could take your ANNUAL DISTRIBUTION from either account in your SEPP 72-T UNIVERSE, such as taking it all from the larger account. Or, one of the accounts could have CDs, bonds, or preferreds that mature and generate cash for distributions without having to sell securities, mutual funds or ETFs (which were increasing in value, until recently).