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    IRA One-Rollover-Per-Year Rule

    I have a financial planning client who dropped into my office to review his current investments and upcoming college funding needs. I did not prepare his returns (H&R Block did). The client is age 52 and his wife is 54. They have several IRAs (Roth, traditional) and non-IRA accounts that are all invested in various annuities (variable and fixed ... no, I did not sell them to him). He is a very conservative investor and an engineer by profession. Two years ago when the twin daughters were age 13, his annuity representative completed paperwork for him to begin annuitizing three of his accounts: two IRA accounts and one non-IRA account.

    The reasoning offered by the client was that he was told this was a way to fund college for the girls. (My guess is that the rep didn't want to 'lock up' the money in another annuity via a 1035 exchange which might start the whole 7- or 10-year surrender charge schedule and then the cash wouldn't be available so readily for college. That ignores the fact that most contracts allow a withdrawal of 10% without annuitizing).

    All three accounts are paying out on a 10-year period certain basis (so they'll be down to zero when he's age 60).

    On his 2013 tax return he showed line 15b total of $16,600 (for the IRA distributions) and line 16a for $13,00 and line 16b for $8,100 (taxable portion).

    He presently does not need the extra cash (didn't need it either when they started this two years ago). His college financial aid base year is a couple of years away but this extra income will not be helping them out at that time either. Add to that the extra tax hit now, and he's not a happy camper.

    So the client is asking about options. He's brought up the 72(t) Substantially Equal distribution rules. I say 'no' he doesn't fall under them. As I understand them, he would need to base them on life expectancy but the distributions are coming out over 10 years. And even that amount withdrawn will be slightly different each year as well.

    He has also found reference to IRS Pub 575:

    An eligible rollover distribution is any distribution of all or any part of the balance to your credit in a qualified retirement plan except:
    1. Any of a series of substantially equal distributions paid at least once a year over:
    a. Your lifetime or life expectancy,
    b. The joint lives or life expectancies of you and your beneficiary, or
    c. A period of 10 years or more,

    He is now asking about the IRA one-rollover-per-year rule (http://www.irs.gov/Retirement-Plans/...er-Year-Rule): Current law

    You don’t have to include in your gross income any amount distributed to you from a traditional IRA if you deposit the amount into another (or the same) traditional IRA within 60 days (Internal Revenue Code Section 408(d)(3)).

    I don't think that provision counts in this case. He is, after all, getting a 1099-R from the insurance company.

    My recommendations were to have him divert $6,500 to a spousal IRA (his wife is over 50, has earned income and does not have a company plan). And divert the remainder to the already existing 529 plans for tax-free compounding and future withdrawals.

    I may be wrong about this but if someone else has any experience with 72(t) or the rollover rule and has a different interpretation, please let me know.

    #2
    I'm not entirely sure what you are asking, but here are my thoughts:


    I agree, the distributions are not over the life expectancy, so a withdrawal would be subject to the 10% penalty.

    I can't find anything that says the distributions can not be rolled over. So from what I read, it would seem that the client CAN roll over the distributions (only do ONE rollover per year!). Receiving a 1099-R doesn't affect the ability to do a rollover. A non-trustee to trustee rollover SHOULD have a 1099-R, and you just indicate on the tax return that it is a rollover.

    I'm not sure about the non-IRA account (depending on what type it is). If it's a retirement account and otherwise would be eligible for rollovers, it should also qualify.

    Comment


      #3
      Tax Treatment of Annuity Distributions

      Thanks for your reply. What I'm asking about are any ways to characterize the distributions in a way that doesn't subject them to tax.

      So, is there any way that the 10-year period certain IRA annuity distributions can be classified as 72(t)? If so, then the client would not be subject to the early withdrawal penalty. I briefly spoke with a CPA in a study group yesterday who thought that may depend on the rule about claiming 72(t) right from the beginning (which was 2 years ago).

      On the other hand, can the distributions from the IRA annuity (which come out once per year in a lump sum) be rolled within the 60 days of receipt into another IRA under the once-per-year-rule? If so, then the 1099-R matches up with a 5498 from the new (non-annuity) IRA custodian and the whole amount is not subject to any income tax or penalty. The same CPA and several other CFP(r) pros at the same group meeting seemed to think that would be possible provided that the annuity distributions were indeed only coming in one lump sum per year.

      Comment


        #4
        The question is answered in your OP, to wit:

        As stated in Pub 575, ..."an eligible rollover is any distribution.......except one ......which is over ......a period of 10 years or more."

        This was set up at his age 50 and qualifies for 72(t) treatment. It should not be subject to a penalty as long as it remains in this type of payment plan, and is not prematurely distributed before his age 59 1/2. But it cannot be rolled over. Form 8606 should have been completed with each return unless the 1099R code was 2. You might want to check out Revenue Ruling 2002-62 about a one-time change to determine if this would be beneficial to your client.
        Last edited by Burke; 10-03-2014, 05:00 PM.

        Comment


          #5
          Wow, I don't know what happened to my thinking. :-(

          I first started out citing the same thing as Burke (Publication 575). For some reason, I talked myself out of it an gave the opposite answer, and I can't figure out what changed my mind. I should know better than to respond to retirement questions. :-)

          Burke - With a 10 year payout rather than a 'life expectancy' payout, why isn't it subject to the 10% penalty?

          Comment


            #6
            Originally posted by TaxGuyBill View Post
            Burke - With a 10 year payout rather than a 'life expectancy' payout, why isn't it subject to the 10% penalty?
            Because 72(t)(2)(A)(iv) says so. Pull up Revenue Ruling 2002-62 for a full explanation of this.

            Comment


              #7
              Originally posted by TaxGuyBill View Post
              Wow, I don't know what happened to my thinking. :-(

              I first started out citing the same thing as Burke (Publication 575). For some reason, I talked myself out of it an gave the opposite answer, and I can't figure out what changed my mind. I should know better than to respond to retirement questions. :-)

              Burke - With a 10 year payout rather than a 'life expectancy' payout, why isn't it subject to the 10% penalty?
              So, in short, he can't do any rollover to shelter the distribution. But he can qualify for 72(t), pay income tax but avoid the penalty. (Sorry, I usually find I have to repeat things for them to sink in). I understand that there are caveats about 72(t) providing that he doesn't change the payout significantly, continues it for at least 5 years (or 59 1/2) and doesn't miss any distributions.

              I guess by this logic he may also be eligible to file amended returns for the first two years of distributions in order to reclaim the extra tax penalty.

              Comment


                #8
                Originally posted by Burke View Post
                Because 72(t)(2)(A)(iv) says so. Pull up Revenue Ruling 2002-62 for a full explanation of this.
                I'm really sorry, but I'm still missing it. Maybe I need to sleep on this and read things with a 'fresh' mind.

                I keep reading that that in order to qualify, the payout needs to be over the "life expectancy" of the taxpayer. That would be much more than the 10 year payout that the taxpayer is receiving, so I read that it would not qualify.

                Am I missing something? Would it be possible for you to point out a specific point that says a 10 year payout (LESS than the life expectancy) qualifies for the penalty exception?

                Again, maybe I just need to sleep on it.

                Thank you for your patience with me. :-)

                Comment


                  #9
                  Sorry, it's me again.


                  Okay, Publication 575 (which is for PENSIONS, not IRAs) says "An eligible rollover distribution is any distribution of all or any part of the balance to your credit in a qualified retirement plan except ... A period of 10 years or more."



                  An IRA is NOT a "qualified retirement plan".



                  §1.408-4(b): "(b) Rollover contribution—
                  (1) To individual retirement arrangement. Paragraph (a)(1) of this section
                  {includable in taxable income} shall not apply to any amount paid or distributed from an individual retirement account or individual retirement annuity to the individual for whose benefit the account was established or who is the owner of the annuity if the entire amount received (including the same amount of money and any other property) is paid into an individual retirement account, annuity (other than an endowment contract), or bond created for the benefit of such individual not later than the 60th day after the day on which he receives the payment or distribution.

                  That was the basis of my first response. I think the IRA distributions ARE eligible for rollover, and if they are included as taxable income, there would be no penalty. The non-IRA one may not be eligible.


                  Am I misreading it? What do you think?

                  Comment


                    #10
                    Originally posted by TaxGuyBill View Post
                    Sorry, it's me again.


                    Okay, Publication 575 (which is for PENSIONS, not IRAs) says "An eligible rollover distribution is any distribution of all or any part of the balance to your credit in a qualified retirement plan except ... A period of 10 years or more."



                    An IRA is NOT a "qualified retirement plan".



                    §1.408-4(b): "(b) Rollover contribution—
                    (1) To individual retirement arrangement. Paragraph (a)(1) of this section
                    {includable in taxable income} shall not apply to any amount paid or distributed from an individual retirement account or individual retirement annuity to the individual for whose benefit the account was established or who is the owner of the annuity if the entire amount received (including the same amount of money and any other property) is paid into an individual retirement account, annuity (other than an endowment contract), or bond created for the benefit of such individual not later than the 60th day after the day on which he receives the payment or distribution.

                    That was the basis of my first response. I think the IRA distributions ARE eligible for rollover, and if they are included as taxable income, there would be no penalty. The non-IRA one may not be eligible.


                    Am I misreading it? What do you think?
                    Very helpful. Thanks.

                    Comment


                      #11
                      "(iv) part of a series of substantially equal periodic payments (not less frequently than annually) made for the life (or life expectancy) of the employee or the joint lives (or joint life expectancies) of such employee and his designated beneficiary,"

                      The 10-year thing sounds familiar so I assume that's right, but I also get hung up on the life expectancy.

                      RR 2002-62 gives three methods.

                      SECTION 2. METHODS
                      .01
                      General rule.
                      Payments are consid-
                      ered to be substantially equal periodic pay-
                      ments within the meaning of
                      § 72(t)(2)(A)(iv) if they are made in ac-
                      cordance with one of the three calcula-
                      tions described in paragraphs (a) – (c) of
                      this subsection (which is comprised of the
                      three methods described in Q&A–12 of No-
                      tice 89–25).

                      Method a "The annual payment for each year
                      is determined by dividing the account bal-
                      ance for that year by the number from the
                      chosen life expectancy table
                      for that year."

                      Method b "The
                      annual payment for each year is deter-
                      mined by amortizing in level amounts the
                      account balance over a specified number of
                      years determined using the chosen life ex-
                      pectancy table
                      and the chosen interest rate."

                      Method c "The
                      annual payment for each year is deter-
                      mined by dividing the account balance by
                      an annuity factor that is the present value
                      of an annuity of $1 per year beginning at
                      the taxpayer’s age and continuing for the
                      life of the taxpayer (or the joint lives of the
                      individual and beneficiary). The annuity fac-
                      tor is derived using the mortality table in
                      Appendix B
                      and using the chosen interest
                      rate."

                      Where does the 10-year rule come from?

                      Comment


                        #12
                        The 10 year rule is for employee PENSIONS, in §402(c)(4).

                        Comment


                          #13
                          The 72)t) is very tricky.
                          He had better be sure he follows the rules precisely.

                          Here is a link to a fantastic site discussing 72(t) withdrawals.
                          It helps head off many of the pitfalls which can destroy the plan and cost huge penalties.

                          "The only function of economic forecasting is to make astrology look respectful" - John Kenneth Galbraith

                          Comment


                            #14
                            Boy, what am I missing here? It has always been my understanding that all distributions from an IRA to its owner are eligible to be rolled over into another IRA (or back into the same IRA) within 60 days, except for RMDs and the removal of previous, excess contributions.
                            Roland Slugg
                            "I do what I can."

                            Comment


                              #15
                              Originally posted by Roland Slugg View Post
                              Boy, what am I missing here? It has always been my understanding that all distributions from an IRA to its owner are eligible to be rolled over into another IRA (or back into the same IRA) within 60 days, except for RMDs and the removal of previous, excess contributions.
                              Roland, you didn't miss anything. I'm just trying to be sure before providing the advice to the client. I think that the best option is to roll the IRA distribution to another IRA. It may seem obvious but I want to be sure that I wasn't missing anything. H&RB obviously didn't comment on thins when they prepared taxes these past two seasons. (For the non-IRA annuity distribution, I don't think I can offer much more than using some of the money for a spousal IRA and the balance as a contribution to his children's existing 529 plan).

                              And it was the client who keeps reading the IRS pubs and making reference to the 72(t) regs and I still don't think that's a workable option.

                              Comment

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