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Q. Are there any IRS filing requirements? 

A. That depends on how form 1099-R is coded when you receive it from the Trustee/Custodian that is making the SEPP distributions. If 1099-R box 7 is coded with a 2 (Early distribution, exception applies under age 591/2) then nothing additional needs to be filed. If however, box 7 has a code of 1 (Early distribution, no known exception) you must file IRS Form 5329 to claim the exemption to the 10% penalty tax. 
Plan early. Before taking any distributions, confirm whether the account’s trustee/custodian will use code 2 on the 1099-R. If not, prepare to file form 5329. 

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