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New SEPP

L1: New SEPPCould you kindly review my numbers and comment on question at end of post.
DOB 4/8/1960
Beneficiary DOB 1/28/1961
1st Distribution 8/3/2015 ($183,322.74)
Amortization method
Single life
120% AFR=2.12%
Account balance $4M
Annual distribution $183.322.74
1st year will NOT be treated as stub year
1st modification date 8/4/2020
I will likely take these as lump sum distributions each year with the timing being somewhat dependent on market conditions. 2019 will be the final year I take a distribution. I cannot pull anything else from the IRA until 8/4/2020.
I have considered taking monthly distributions in 1/12 increments ($15,276.90/mo).
Would you please comment on the FAQ from IRS concerning SEPP’s.
Kind regards and thanks
Can I take my substantially equal payments on a monthly basis?
The simple answer is yes. Your monthly payment under the required minimum distribution method would be the calculated annual amount divided by 12. Under the amortization and annuity methods, the choice of a having the payment made monthly should be part of the original calculation.(Text made bold by me for emphasis)2015-07-10 19:03, By: Mackster, IP: [174.16.60.60]

L2: New SEPPMerely take the annual distribution (for all methods) and divide by 12, by 4 , by 6 or take as needed as long as you take the annual amount by 12/31.
If you use the adjusted interest rate as published, then you lose some flexibility. Rev.Rul. 2002-62 and IRS Notice 89-25 only talk about annual distributions.
From our FAQ…
Q. Can distributions be made monthly?A.While payments must be made at least annually, several letter rulings address the subject of monthly payments.

PLR8919072- The annual distribution amount was distributed as 12 equal monthly payments.
PLR9050030- The distributions were calculated as monthly distributions using a monthly compounding rate. In this ruling the remaining life expectancy was was converted to months by converting the fractional life expectancy to the nearest whole month.
PLR200105066- The annual distribution was divided by 12 with the first payment to be made in July – only six payments were made in year 1 with the second annual payment calculated in January of the following year.
2015-07-10 19:16, By: Gfw, IP: [205.178.65.222]

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