Rollover from IRA with SEPP

L1: Rollover from IRA with SEPPIt is my understanding that there is not a problem rolling the assets in one IRA (from which SEPPs are being made) to another IRA, provided that the methodology for making SEPPs remains consistent (contrary to some of the sloppy language contained in Rev. Rul. 2002-62 – reviewed William Stecker’s Changes to Account Balance article). I also believe that there is not a problem establishing sub-accounts within the IRA and merely taking distributions from one of the sub-accounts, provided that the full balance of the IRA is considered for purposes of the SEPP. Is there any statutory guidance on these issues? The fact that there is a consistent methodology for making distributions seems to me to meet the language in IRC section 72(t)(4) and the intent of the IRS but I don’t want to gamble with someone else’s money. Thanks much!2006-03-30 12:56, By: Brian, IP: [65.107.70.130]
L2: Rollover from IRA with SEPPHi Brian.
When you say “sub-accounts within the IRA,” what exactly do you mean? Are you using a brokerage account platformcontaining different investments? Or are you using several unique IRA accounts held at different sponsors / custodians? If the later, then you are probably creating a mess. If the former then it works quite well.
Please clarify what structure you are trying to build.
Jim 2006-03-30 14:23, By: Jim, IP: [70.184.1.35]

L2: Rollover from IRA with SEPPHello Jim, The sub-accounts are all within the same IRA brokerage account; just different investments to utilize the skills of managers who focus on particular types of investments. Thank you very much for your input.2006-03-30 14:29, By: Brian, IP: [65.107.70.130]

L2: Rollover from IRA with SEPPGreat. You only have one “IRA Account” and you may change the investments as necessary over time with no problems that relate to the SEPP.
Jim2006-03-30 14:34, By: Jim, IP: [70.184.1.35]

L2: Rollover from IRA with SEPPBrian:
After re-reading your original post, I have this last suggestion. Don’t start SEPP distributions until AFTER you complete all transfers of the different IRA accounts into the one Brokerage IRA account.
Jim2006-03-30 14:38, By: Jim, IP: [70.184.1.35]

L2: Rollover from IRA with SEPPIs there definitive guidance that I am missing or is it merely intuitive? I guess I am stuck on the “any nontaxable transfer of a portion of the account balance to another retirement plan” language in Rev. Rul. 2002-62. I have reviewed PLRs that discuss rollovers from retirement plans to IRA (I couldn’t find one “on point” with respect to an IRA to IRA rollover but the logic is the same) but I was hoping for something more substantial that I can rely on.2006-03-30 14:43, By: Brian, IP: [65.107.70.130]

L2: Rollover from IRA with SEPPYou aren’t changing retirement plans – you are merely changing IRA accounts.2006-03-30 14:47, By: Gfw, IP: [172.16.1.70]

L2: Rollover from IRA with SEPPLet me try this example and see if it fits your situation. I think I may have thrown some mud on your situation and I would like to clean it up.
You have three IRA’s, A – B – C, and each is already set up and making SEPP distributions. You want to transfer all three IRA’s into one IRA using a brokerage platform, then manage the assets within the brokerage account. Just be sure the total, annual distribution from the new brokerage account IRA equals the total distribution amount from the three original IRA’s. This is OK.
The problem you refer to would occur if you transferred part of IRA “B” into IRA “D” ora K-plan, etc.,that was NOT part of the SEPP universe.
Hope this helps.
Jim2006-03-30 15:17, By: Jim, IP: [70.184.1.35]

L2: Rollover from IRA with SEPPThank you very much for the input!2006-03-30 16:30, By: Brian, IP: [65.107.70.130]