Multiple 72(t)s allowed?
L1: Multiple 72(t)s allowed?Forgive me if this question has already been asked but, I’m not sure if multiple 72(t)s are allowed.
For example, let’s say that I have $500,000 in one IRA (no other retirement accounts, just that one). Then, I split out $50k into a separate IRA, and do a 72(t) starting on 1/31/2017, based on the second IRAs balance on 12/31/16 (with the proper calculations, et al). So, the remaining $450k isn’t an issue. [Further assume that I turn 50 in 2017, and take a full year contribution, with no stub year or pro-rated distributions.]
Then, next year, I want to split out say another $100k into a third IRA, and calculate that 72(t) withdrawal on 1/31/2018 based on the third IRAs balance on 12/31/17 (properly calculated). Leaving the remaining $350k out of the picture.
So, in Jan 2018, I would receive two distributions from two different IRAs, each with it’s own SEPP calculation (for simplicity sake, let’s say it’s one of the “fixed” amounts) – Is that acceptable?
Assuming I get two “code 1” 1099s, would I fill out just one Form 5329, or should I fill out two.
I can see a correspondence audit easily happening, but I just wanted to make sure this was acceptable. Part of the concern is that you’re allowed to make the distribution from a different IRA account, even if the calculation(s) are based on the 72(t) account(s).
I can see it get confusing fast but, it seems like this approach would be legal from a tax perspective – Just a matter of walking the IRS through it, with FULL documentation.
[In my case, I’d probably take the distributionsas cleanly as possible, and not muck about with other IRAs.]
Part of the reason I want to evaluate this option is the low interest rates – So, take just enough to meet living expenses (paired with non-qual assets), while managing taxes, and evaluate each year for say 10 years. Yes, that’s potentially 10 different 72(t)s, with a host of paperwork but, is it legal/acceptable to do so?
Thanks!2016-07-08 14:53, By: Craig, IP: [188.8.131.52]
L2: Multiple 72(t)s allowed?Yes, you can establishmultiple separate 72t accounts at either the same time or at different times. The IRS has not specified anykind of limit to the number of plans you can operate at the same time.Each would be totally separate from the others and separately documented. If you busted one of them, it would have no affect on the others, so this is a way to hedge against a potential huge penalty. That said, having several plans operating at the same time is rare, and might invite an IRS inquiry. If that happened, and you had to produce your calculations for each plan, some of the hedging benefits of several plans is offset. Youalso have an increased operational exposure which increases proportionately for each plan you add. Gettingthe accounts mixed up in any way would bust the plans that did not comply.You could fill out a single 5329 for all the 1099R forms coded 1 where the 02 SEPP exception waives the penalty.2016-07-08 17:49, By: Alan S, IP: [184.108.40.206]
L2: Multiple 72(t)s allowed?Almost everything that you stated is correct. However, even though you can satisfy RMD requirements after age 70 1/2 by taking distributions from either one or several IRA accounts, I believe that you must take SEPP 72-T distributions only from the IRA account(s) that were set up initially in its “universe”.
I believe that each account requires its own 5329, but even if not, I think it might be better to file separate ones because I do not trust that the IRS has the capability to understand that you are filing for multiple plans.2016-07-08 17:49, By: dlzallestaxes`, IP: [220.127.116.11]
L3: Multiple 72(t)s allowed?I had two SEPP plans. Started one in March 2006, when I retired.I started a second SEPPwhen I bought a second home in May 2007 andused a second IRA I had at a different custodian where I had already separated some IRA $ just for that purpose or for “as needed” extra withdrawals with only penalty on that withdrawal. First one gave me code 2, so no need for 5329. The one with Vanguard had code 1, so I filed a 5329 each year on that one. First one ended in 2011 (5 yrs) and second one ended in 2012, also 5 yrs. All went well. The 2006 one was back in the “good old days” when I used an INT rate in my calcs for AMORT of 5.39% from JAN 2006. I changed the AMORT to MIN DISTRIB in last two years on the first one, all without a hitch (after we sold our first home and consolidated to one house). This web site was very helpful in educating me before I even started. Thank you GORDON!!
2016-07-10 21:56, By: Ken, IP: [18.104.22.168]