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People should try and honestly figure out for themselves what they intend to do about infirmity because it can be really expensive. Since I prefer to die rather than rot away in a Nursing home or e.g from cancer, I discount those costs.
Good point. Nursing home costs in this area average $130K per year per individual. Last week, three elder care facilities in our small state closed--lack of staff and/or unsustainable operating costs. Not a bright future.
 
There's no penalty if the account is depleted, but you'd have to be really bad at investments to do that - the amount that is set for your withdrawals

Oh, I didn't realize that the gov sets the withdrawal rate. It sounds similar to the pension funding planning I had to pay an actuary to do in order to set up a defined benefit plan for my one owner/one employee business.
 
Yes, I started my SEPP withdrawal at age 45 and continued until 60 (to be absolutely sure I was past age 59 1/2). The amount was amortized based on a 6.5% interest rate, which was a reasonable figure back in the days of higher rates. Even over that fairly long span, my IRA balance grew. I believe there is a provision in SEPP that allows a one-time adjustment to the withdrawal rate without penalty, to guard against drastic changes to the account balance, although I haven't read up on it in years.

SEPP was the reason I was able to retire at 45. That and being thrifty. My withdrawal amount was $14,228 per year, which was more than I needed in the early years but about right in the later years (something to consider when living on a fixed payment for many years). I still remember that number because it was the same for sixteen years. You can do monthly withdrawals but I preferred the simplicity of one per year; I generally took it at the end of the year to allow for the account to grow more. I raised cash from my investments by selling during the year, to have enough for the annual SEPP distribution. Makes for challenging financial planning!

One more wrinkle on SEPP: if you have more than one taxable IRA, you can apply SEPP to just one and leave the other(s) as a reserve. It helps to roll 401(k)s into separate IRAs to preserve maximum flexibility. FWIW.
Yeah, you can do a one time switch to RMD which is variable (and has the lowest initial payout), and can help extend things if the account value drops due to market losses.
 
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Oh, I didn't realize that the gov sets the withdrawal rate. It sounds similar to the pension funding planning I had to pay an actuary to do in order to set up a defined benefit plan for my one owner/one employee business.
Yes, they use actuarial tables to assume how long you (and your spouse, if you choose) will live and the current interest rates to determine your withdrawal amount. For me, using single life and the fixed amortization method resulted in the highest possible amount that I could withdraw per year. That number will remain fixed until I turn 59.5. You can also change from either of the fixed amounts to the RMD method once during the SEPP period.

Actually, you can make any changes you want to the SEPP, but you WILL face hefty IRS penalties for doing so (backdated penalties on ALL years of your SEPP). Keep this in mind before you set one up.

The RMD method seems to always be the lowest amount, but, if your account rises in value over the years, switching to the RMD method could actually raise your withdrawal amount.


 
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Yes, they use actuarial tables to assume how long you (and your spouse, if you choose) will live and the current interest rates to determine your withdrawal amount. For me, using single life and the fixed amortization method resulted in the highest possible amount that I could withdraw per year. That number will remain fixed until I turn 59.5. You can also change from either of the fixed amounts to the RMD method once during the SEPP period.

Actually, you can make any changes you want to the SEPP, but you WILL face hefty IRS penalties for doing so (backdated penalties on ALL years of your SEPP). Keep this in mind before you set one up.

The RMD method seems to always be the lowest amount, but, if your account rises in value over the years, switching to the RMD method could actually raise your withdrawal amount.


A couple of folks with SEPP experience! I'm wanting to set one up and am stuck on the most mechanical of stuff. I've found the calculators online so I have a good idea of what sort of annual withdrawal I can take. However - is there an IRS form that I send in with my taxes the first year declaring that I'm starting an SEPP, the amount I'm basing on, my withdrawal rate - the stuff the IRS would need to know, so they also know I'm not cutting corners?

Or do I just start taking withdrawals and at tax time I tell them the withdrawal is an SEPP and not subject to the 10% penalty, and then I have my detailed calculations at hand when/if audited?


I'd like to be able to set this up myself, or with the help of my own hired professional. Any pointers or insights into the mechanics of establishing and operating these would be hugely appreciated.
 
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A couple of folks with SEPP experience! I'm wanting to set one up and am stuck on the most mechanical of stuff. I've found the calculators online so I have a good idea of what sort of annual withdrawal I can take. However - is there an IRS form that I send in with my taxes the first year declaring that I'm starting an SEPP, the amount I'm basing on, my withdrawal rate - the stuff the IRS would need to know, so they also know I'm not cutting corners?

Or do I just start taking withdrawals and at tax time I tell them the withdrawal is an SEPP and not subject to the 10% penalty, and then I have my detailed calculations at hand when/if audited?


I'd like to be able to set this up myself, or with the help of my own hired professional. Any pointers or insights into the mechanics of establishing and operating these would be hugely appreciated.
I have not had a full year under this plan, so I can't speak about filing taxes, but setup was really easy. I contacted Fidelity, where my IRA is located, they pointed me to a form on their website (or they could have emailed it to me), which I had to print, fill out, sign, and mail in. They sent me a letter a week or so later confirming my choices and then I just waited for the direct deposits to begin.

I had previously set up my checking account as able to accept funds from Fidelity - that was a whole other process - at the time I had to physically go to one of their offices to prove who I was. I don't know what their procedures are now, mid-pandemic.
 
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I have not had a full year under this plan, so I can't speak about filing taxes, but setup was really easy. I contacted Fidelity, where my IRA is located, they pointed me to a form on their website (or they could have emailed it to me), which I had to print, fill out, sign, and mail in. They sent me a letter a week or so later confirming my choices and then I just waited for the direct deposits to begin.

I had previously set up my checking account as able to accept funds from Fidelity - that was a whole other process - at the time I had to physically go to one of their offices to prove who I was. I don't know what their procedures are now, mid-pandemic.
Yeah - I'm with Fidelity also but I'm also looking to move the retirement accounts to a new broker with lower fees. I'm pretty sure that the new broker won't do the paperwork to set one of these up, so I'm hoping to find insight into those mechanics.

Thanks!
 
Oh, I didn't realize that the gov sets the withdrawal rate. It sounds similar to the pension funding planning I had to pay an actuary to do in order to set up a defined benefit plan for my one owner/one employee business.
That isn't strictly true. There are constraints and three IRS accepted methods for calculating SEPP:

(From the Investopedia link from @CarlS above.)

Calculation for Payment Amounts Under Rule 72(t)​


The amounts an account holder receives in the periodic payments enabled by rule 72(t) depend on life expectancy, which can be calculated through one of three IRS-approved methods:

  • The amortization method
  • The minimum distribution (or the life expectancy method)
  • The annuitization method

The amortization method determines yearly payment amounts by amortizing the balance of an IRA owner’s account over single or joint life expectancy. This method develops the largest and most reasonable amount an individual can remove, and the amount is fixed annually.


The minimum distribution method takes a dividing factor from the IRS’s single or joint life expectancy table, using it to divide the retirement account’s balance. This method is nearly the opposite of the amortization method, as the annual early withdrawal payments are likely to vary from year to year, though not substantially. The key difference between this method and the amortization method is the resulting payments with the minimum distribution method, as the name implies, are the lowest possible amounts that can be withdrawn.

The final IRS-approved calculation is the annuitization method, which uses an annuity factor method provided by the IRS to determine equivalent or nearly equivalent payments in accordance with the SEPP regulation. This method offers account holders a fixed annual payout, with the amount typically falling somewhere between the highest and lowest amount the account owner can withdraw.
In my case the "life expectancy method" (same as RMD calculations using life expectancy tables), while easiest to figure, provided too little to live on given my young age — the younger you are, the lower the percentage you can take out, for obvious reasons — longer life expectancy.

It wasn't until I found that I could use the "amortization" method instead that I realized that I could take out a much higher payment. The amortization calculation is dependent on the interest rate used and that, in turn, has limits. However, if the maximum interest rate allowed generates a payment higher than needed/wanted, you are able to use a lower figure. I settled on my 6% based on it being enough for my purposes and below the highest rate allowed by IRS guidelines at the time.

So, there is some flexibility in setting up the initial payment scheme. After that you have to stick with it, save for the single exception mentioned by @mongo above. The penalties for missing a payment are severe; in my opinion SEPP is only for detailed-oriented people who absolutely will be able to make the required payments on time!
 
Yeah - I'm with Fidelity also but I'm also looking to move the retirement accounts to a new broker with lower fees. I'm pretty sure that the new broker won't do the paperwork to set one of these up, so I'm hoping to find insight into those mechanics.

Thanks!
I found this:

If I'm interpreting this correctly then I can take my own withdrawals on a schedule, and those withdrawals will be reported on 1099-R. Ideally the brokers already knows these are SEPP withdrawals and thus not subject to the 10% penalty, but it also looks like I can tell the IRS that the withdrawals are SEPP withdrawals (even if the broker doesn't code them that way) and not subject to the 10% penalty.

I'd use whatever scheduling function the broker has to make withdrawals of the correct size at the correct frequency (I'll probably do quarterly rather than annual).


It's these sorts of mechanics that I'm trying to understand. (Thanks again)
 
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A couple of folks with SEPP experience! I'm wanting to set one up and am stuck on the most mechanical of stuff. I've found the calculators online so I have a good idea of what sort of annual withdrawal I can take. However - is there an IRS form that I send in with my taxes the first year declaring that I'm starting an SEPP, the amount I'm basing on, my withdrawal rate - the stuff the IRS would need to know, so they also know I'm not cutting corners?

Or do I just start taking withdrawals and at tax time I tell them the withdrawal is an SEPP and not subject to the 10% penalty, and then I have my detailed calculations at hand when/if audited?


I'd like to be able to set this up myself, or with the help of my own hired professional. Any pointers or insights into the mechanics of establishing and operating these would be hugely appreciated.
My recollection is that you set it up and just start taking distributions. When you take a distribution you specify what it is for to the account company (Fidelity, in my case). When you get your 1099R for the account Box 7 will have a code in it. You want it to be a "2" (early distribution exception applies). Mine got marked "1" (early distribution no known exception). Perhaps this was because I didn't have Fidelity set up the SEPP, I just did it on my own, can't say.

Each year, as part of my tax return, I filed Form 5329 "Additional Taxes on Qualified Plans (Including IRAs) and Other Tax-Favored Accounts". On line 2, the taxable amount of the distribution, I entered "2" as the exception number. I believe that I had to file that form because my 1099R was mis-marked with a "1", to verify that I qualified for an exception.

My guess is that if you get a 1099R with a "2" in box 7 you won't need to file that form. In my case Fidelity didn't know for sure that the SEPP exception applied so they marked it with a 1.

Please be aware that things may have changed since I took my last SEPP distribution years ago.


Edit: Since I turned 59½, box 7 on my 1099R form has been marked with a "7" (Normal distribution).
 
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So, there is some flexibility in setting up the initial payment scheme. After that you have to stick with it, save for the single exception mentioned by @mongo above. The penalties for missing a payment are severe; in my opinion SEPP is only for detailed-oriented people who absolutely will be able to make the required payments on time!
It varies by firm, but Vanguard lets you set up auto distributions. The most timing critical part is selling holdings to fund the money market account in time for it to settle and be transferred out. Still, the only issue is procrastination.
 
My recollection is that you set it up and just start taking distributions. When you take a distribution you specify what it is for to the account company (Fidelity, in my case). When you get your 1099R for the account Box 7 will have a code in it. You want it to be a "2" (early distribution exception applies). Mine got marked "1" (early distribution no known exception). Perhaps this was because I didn't have Fidelity set up the SEPP, I just did it on my own, can't say.

Each year, as part of my tax return, I filed Form 5329 "Additional Taxes on Qualified Plans (Including IRAs) and Other Tax-Favored Accounts". On line 2, the taxable amount of the distribution, I entered "2" as the exception number. I believe that I had to file that form because my 1099R was mis-marked with a "1", to verify that I qualified for an exception.

My guess is that if you get a 1099R with a "2" in box 7 you won't need to file that form. In my case Fidelity didn't know for sure that the SEPP exception applied so they marked it with a 1.

Please be aware that things may have changed since I took my last SEPP distribution years ago.


Edit: Since I turned 59½, box 7 on my 1099R form has been marked with a "7" (Normal distribution).
This is awesome info and exactly the sort of thing I was looking for. I've found the IRS site with the details on doing the calculation, so I'm confident I can do that end of things.
 
It varies by firm, but Vanguard lets you set up auto distributions. The most timing critical part is selling holdings to fund the money market account in time for it to settle and be transferred out. Still, the only issue is procrastination.
Agree. The reason I wanted nothing to do with automatic distributions is that I had to decide what to sell and when, and wanted compete control over that process. Back then I didn't keep cash in money market funds earning little, save for right before I wanted to take a distribution at the end of the year (December).

Nowadays I keep some cash to take advantage of market or individual stock/fund corrections (March 2020, for example), since the markets are crazy high, by my standards. I prefer to buy stocks and stock funds when they are "on sale."
 
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Agree. The reason I wanted nothing to do with automatic distributions is that I had to decide what to sell and when, and wanted compete control over that process. Back then I didn't keep cash in money market funds earning little, save for right before I wanted to take a distribution at the end of the year (December).

Nowadays I keep some cash to take advantage of market or individual stock/fund corrections (March 2020, for example), since the markets are crazy high, by my standards. I prefer to buy stocks and stock funds when they are "on sale."
Couple of incremental things I've learned / figured out for my own situation.

1) For funding the periodic withdrawals, that'll be easy for me. I'm maintaining a cash balance that I use to sell puts against. The annual withdrawal amount is small enough that leaving enough cash unencumbered is pretty straightforward.

2) A general note for all - the SEPP looks like a pretty bad idea against a ROTH IRA. You'd avoid the 10% early withdrawal penalty, and you can still withdraw the contributions that you make. But the SEPP withdrawals show up as ordinary income that you'll pay taxes on, rather than the cash with no taxes due that you can get once you reach 59 1/2.

In my case the ROTH constraint is sort of big - through sheer dumb luck (I wish I'd planned it this way - at least it happened this way), our original TSLA purchase in 2012 is in our ROTH. That position is my first, and my second, 10 bagger. That account has grown .. big.
 
^ A lot depends on your tax situation. In general, it is best to keep a Roth IRA growing tax-free and draw, slowly, from a taxable IRA (via SEPP plan if younger than 59½). The idea is to take money out of the taxable IRA a little at a time to keep the tax bracket low — in my case my withdrawal was fairly small and, thus, my tax bracket was micoscopic.

One reason for doing this is that at age 72 (used to be 70½) one must begin Required Minimum Distributions (RMD). If you have depleted your taxable IRAs before this age (as I have) you don't need to fuss with RMDs. [I trust that it is understood that Roth IRAs are completely exempt from RMD.]

Another way to deplete the taxable IRAs before RMD age is to gradually convert some of the money to a Roth IRA, taking care to do only enough each year to stay in a low tax bracket. If you do this over enough years the tax hit can be quite low, assuming a low income, as is the case for many who have retired young — little or no earned income and no Social Security income yet. The calculations might be different for those few who have pension income.

Even if you can't fully deplete your taxable IRAs, just lowering the size will reduce the amount of the required RMDs and reduce the resulting tax hit. It isn't an either/or situation.
 
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Couple of incremental things I've learned / figured out for my own situation.

1) For funding the periodic withdrawals, that'll be easy for me. I'm maintaining a cash balance that I use to sell puts against. The annual withdrawal amount is small enough that leaving enough cash unencumbered is pretty straightforward.

2) A general note for all - the SEPP looks like a pretty bad idea against a ROTH IRA. You'd avoid the 10% early withdrawal penalty, and you can still withdraw the contributions that you make. But the SEPP withdrawals show up as ordinary income that you'll pay taxes on, rather than the cash with no taxes due that you can get once you reach 59 1/2.

In my case the ROTH constraint is sort of big - through sheer dumb luck (I wish I'd planned it this way - at least it happened this way), our original TSLA purchase in 2012 is in our ROTH. That position is my first, and my second, 10 bagger. That account has grown .. big.

Thanks for the info on the Roth.. :oops:

I was planning on doing the 72-t but all my IRA money has been rolled over to the Roth over the years and like you, my earliest purchases in TSLA have been in the Roth..
 
2) A general note for all - the SEPP looks like a pretty bad idea against a ROTH IRA. You'd avoid the 10% early withdrawal penalty, and you can still withdraw the contributions that you make. But the SEPP withdrawals show up as ordinary income that you'll pay taxes on, rather than the cash with no taxes due that you can get once you reach 59 1/2.
Did you get that from the moneycrashers site (first Google result)? I'm pretty sure that is wrong.
[Or incomplete, depending on the status of a non-qualified SEPP withdrawl of earnings]
[[I see, unqualified Roth earnings withdrawls are taxable, and apparently that carries through on the early part of a SEPP also. However, the contributions are the first things withdrawn, so a rollover would start out untaxed + unpenalized with a SEPP (but rollover can have a worse effective tax rate]]

First off, with Roths, the principle is always untaxed and there is no penalty on withdrawl at any time. For a rollover amount, it needs to age 5 years or you're over 59.5 . For earnings, they need to sit 5 years from the first contribution and be over 59.5. So, you do not need a SEPP to pull direct contributions from a Roth nor rollover amounts older than 5 years.
A SEPP plan allows distributions from earnings before 59-1/2 without the penalty and retains the Roth tax free status. (May remove the 5 year rule too?)
Publication 590-B (2020), Distributions from Individual Retirement Arrangements (IRAs) | Internal Revenue Service
Other early distributions.
Unless one of the exceptions listed below applies, you must pay the 10% additional tax on the taxable part of any distributions that aren't qualified distributions.

Exceptions.
You may not have to pay the 10% additional tax in the following situations.
  • snip
  • The distributions are part of a series of substantially equal payments.
https://advisor.morganstanley.com/t...antic-group/912950-72tdistributions-guide.pdf
CAN I TAKE 72(t) DISTRIBUTIONS FROM A ROTH IRA? 72(t) distributions can be taken from Roth IRAs in essentially the same manner as Traditional IRAs. However, since Roth IRA contributions can generally be withdrawn without incurring any income taxes or penalty taxes and Roth IRA distributions are always treated as consisting first of contributions, this strategy need only be used for a Roth IRA if you are under age 59 ½ and want to withdraw earnings (or certain converted amounts during the 5-year period for each conversion contribution) after exhausting contributions.

Using 72(t) Rules For Penalty-Free Income | Bankrate.com
Also, your Roth IRA allows you to take out all the money you’ve contributed without paying taxes or penalties, so setting up a 72(t) might be unnecessary.

A few things to keep in mind: Withdrawals under this method may avoid penalties, but they don’t avoid income taxes (except when taken from the Roth). Also, early withdrawals from retirement funds increase the odds you’ll run out of money, particularly if your investments do poorly.
 
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Did you get that from the moneycrashers site (first Google result)? I'm pretty sure that is wrong.
[Or incomplete, depending on the status of a non-qualified SEPP withdrawl of earnings]

First off, with Roths, the principle is always untaxed and there is no penalty on withdrawl at any time. For a rollover amount, it needs to age 5 years or you're over 59.5 . For earnings, they need to sit 5 years from the first contribution and be over 59.5. So, you do not need a SEPP to pull direct contributions from a Roth nor rollover amounts older than 5 years.
A SEPP plan allows distributions from earnings before 59-1/2 without the penalty and retains the Roth tax free status. (May remove the 5 year rule too?)
Publication 590-B (2020), Distributions from Individual Retirement Arrangements (IRAs) | Internal Revenue Service

https://advisor.morganstanley.com/t...antic-group/912950-72tdistributions-guide.pdf


Using 72(t) Rules For Penalty-Free Income | Bankrate.com
Thank you for challenging me on this @mongo.

Some searching and yes, I think that came from the moneycrashers site. I've always believed that ROTH withdrawals via SEPP were were not taxed.

Looking for more info led me here:

I looked at the IRS stuff and I didn't find that clear on this very specific point. The Morgan Stanley stuff also looks ambiguous to me on this point:
CAN I TAKE 72(t) DISTRIBUTIONS
FROM A ROTH IRA?
72(t) distributions can be taken from
Roth IR As in essentially the same
manner as Traditional IR As. However,
since Roth IR A contributions can
generally be withdrawn without incurring
any income taxes or penalty taxes and
Roth IR A distributions are always treated
as consisting first of contributions, this
strategy need only be used for a Roth
IR A if you are under age 59 ½ and
want to withdraw earnings (or certain
converted amounts during the 5-year
period for each conversion contribution)
after exhausting contributions.

I read this as:
1) yes you can take distributions
2) the contributions can be withdrawn penalty and income tax free (In my case, I don't care - the original contributions are trivial)
3) The money line that could have made this clear -- 'only be used for a Roth .. want to withdraw earnings after exhausting contributions'.

They -could- have said what when earnings were distributed via SEPP they would be income tax free.


From the IRS Pub:

What Are Qualified Distributions?​


A qualified distribution is any payment or distribution from your Roth IRA that meets the following requirements.
  1. It is made after the 5-year period beginning with the first tax year for which a contribution was made to a Roth IRA set up for your benefit.
  2. The payment or distribution is:
    1. Made on or after the date you reach age 59½,
    2. Made because you are disabled (defined earlier),
    3. Made to a beneficiary or to your estate after your death, or
    4. One that meets the requirements listed under First home under Exceptions in chapter 1 (up to a $10,000 lifetime limit).

This seems to be the full list of qualified distributions (for earnings).


My takeaway - I'm not a tax pro. NOT-ADVICE.

I've always thought that the ROTH withdrawals via SEPP would be income tax free but now I'm unsure. If one has $10k worth of contributions in a $1M account, then the ability to withdraw the $10k with no penalty or income tax owed is kind of trivial. I'll find a tax pro to clear this up before I start a SEPP from my Roth IRA.
 
Thank you for challenging me on this @mongo.

Some searching and yes, I think that came from the moneycrashers site. I've always believed that ROTH withdrawals via SEPP were were not taxed.

Looking for more info led me here:

I looked at the IRS stuff and I didn't find that clear on this very specific point. The Morgan Stanley stuff also looks ambiguous to me on this point:


I read this as:
1) yes you can take distributions
2) the contributions can be withdrawn penalty and income tax free (In my case, I don't care - the original contributions are trivial)
3) The money line that could have made this clear -- 'only be used for a Roth .. want to withdraw earnings after exhausting contributions'.

They -could- have said what when earnings were distributed via SEPP they would be income tax free.


From the IRS Pub:


This seems to be the full list of qualified distributions (for earnings).


My takeaway - I'm not a tax pro. NOT-ADVICE.

I've always thought that the ROTH withdrawals via SEPP would be income tax free but now I'm unsure. If one has $10k worth of contributions in a $1M account, then the ability to withdraw the $10k with no penalty or income tax owed is kind of trivial. I'll find a tax pro to clear this up before I start a SEPP from my Roth IRA.

I think Roth through SEPP will be taxed as income but without the 10% penalty. There is a lot of good info on 72tnet.com. This document https://72tnet.com/wp-content/uploa...-To-SEPPS-and-IRC-72t-Bill-Stecker-4th-ed.pdf is pretty exhaustive but is from 2004 so some things may have changed.

Page 42 of that article talks about qualified vs. unqualified and it seems to me that SEPP is not actually "qualified" by that definition:

A qualified distribution is one that is BOTH:

1. Made after a 5-taxable-year period, and
2. Made on or after the date on which the taxpayer attains the age of 59½, or made to a beneficiary or the estate of the owner on or after the date of the owner’s death, or attributable to the owner’s being disabled, or for a first time home purchase.

An unqualified distribution is any distribution that does not meet the two rules above.


One thing I just noticed on page 96 of that document is the idea of combining a Roth with an IRA for the purposes of increasing the total balance in order to calculate a higher distribution - but then to only take the distributions from the IRA, leaving the Roth untouched and avoiding the unqualified tax issue. Anyone have thoughts on that?
 
Thank you for challenging me on this @mongo.

Some searching and yes, I think that came from the moneycrashers site. I've always believed that ROTH withdrawals via SEPP were were not taxed.

Looking for more info led me here:

I looked at the IRS stuff and I didn't find that clear on this very specific point. The Morgan Stanley stuff also looks ambiguous to me on this point:


I read this as:
1) yes you can take distributions
2) the contributions can be withdrawn penalty and income tax free (In my case, I don't care - the original contributions are trivial)
3) The money line that could have made this clear -- 'only be used for a Roth .. want to withdraw earnings after exhausting contributions'.

They -could- have said what when earnings were distributed via SEPP they would be income tax free.


From the IRS Pub:


This seems to be the full list of qualified distributions (for earnings).


My takeaway - I'm not a tax pro. NOT-ADVICE.

I've always thought that the ROTH withdrawals via SEPP would be income tax free but now I'm unsure. If one has $10k worth of contributions in a $1M account, then the ability to withdraw the $10k with no penalty or income tax owed is kind of trivial. I'll find a tax pro to clear this up before I start a SEPP from my Roth IRA.
Yeah, I double edited my post, so it is updated from your reply. (I should never try thinking before eating)

I thought they would be tax free also, but it appears they retain their tax status. So all contributions are tax free under a 72(t) plan, but earnings are not qualified (tax free) until 5 years and age > 59-1/2 (or other special cases).

So, Roth direct contributions and 5 year old conversions are freely accessible (no SEPP needed), and a SEPP allows penalty free acess to newer than 5 year conversions and earnings (taxed).

The edge case I thought of is a non trustee Roth to Roth transfer, that would theoretically turn the entire balance to a rollover. If such a thing can be reasonably done .

This site has a nice write up (though they use "traditional IRA" at the end producing ambiguity regarding Roth).
https://blog.massmutual.com/post/retire-early-avoid-penalties
It also mentions a thought I had that the 10% penalty might not be so bad in some circumstances.

One thing I just noticed on page 96 of that document is the idea of combining a Roth with an IRA for the purposes of increasing the total balance in order to calculate a higher distribution - but then to only take the distributions from the IRA, leaving the Roth untouched and avoiding the unqualified tax issue. Anyone have thoughts on that?

OH! That's what they were talking about. Interesting approach, since I have a lot of IRAs from individual 401k rollovers, and it would be more flexible not to SEPP all of them. Especially if the balances (or interest rates) grow allowing higher distributions later.