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In General

If you're like most people, individual retirement accounts and individual retirement annuities (IRAs) comprise a significant portion of your retirement nest egg. It's important to understand when you can (and must) begin taking distributions from your IRAs, the tax consequences, and how to incorporate your withdrawals into your retirement income plan.

Caution: Although most states follow the federal income tax treatment of traditional or Roth IRAs, some do not. You should check with your tax advisor regarding the tax treatment of IRAs in your particular state.

Distributions from Traditional IRAs: Prior To Age 59½

The purpose of IRAs is to provide income to help fund your retirement years, and the federal government wants to make sure you use the money for that purpose. If you receive a distribution from your traditional IRA before you reach the age of 59½, the IRS considers this a premature distribution. Like all distributions from traditional IRAs, premature distributions are generally taxable. You will pay federal (and possibly state) income tax on the portion of the distribution that represents tax-deductible contributions, any pre-tax funds that were rolled over into the IRA from an employer-sponsored retirement plan, and investment earnings. In addition to regular income tax, distributions taken prior to age 59½ may be subject to a 10% federal premature distribution penalty tax (and possibly a state penalty) on the taxable portion of the distribution.

The penalty tax is meant to encourage you to leave your money in the IRA until age 59½ or later. This reduces the risk that you will deplete your funds prematurely and run out of money at some point in retirement. The assumption is that by the time you reach age 59½, you are either already retired or near retirement, and can safely begin using your retirement money.

Income taxes on IRA and retirement plan distributions can really add up. When a distribution is also subject to the 10% federal penalty, the portion of the distribution that goes into your pocket obviously dwindles even further. If you are close to age 59½ and wish to take a distribution from your traditional IRA, check the calendar carefully to avoid a potentially costly mistake.

Exceptions to the Premature Distribution Tax, Including SEPPs

Unless you qualify for an exception, taxable amounts you withdraw from a traditional IRA before age 59½ are subject to a federal 10% premature distribution tax (and possibly a state penalty tax, too). This premature distribution tax is assessed in addition to any federal (and possibly state) income tax due. Fortunately, Section 72(t) of the Internal Revenue Code lists several exceptions. For example, the penalty doesn't apply if you have a qualifying disability, or if you use the proceeds to pay certain unreimbursed medical expenses.

However, one of the most important exceptions, from a retirement income perspective, involves taking a series of "substantially equal periodic payments" (SEPPs) from your IRA. This exception is important because it's available to anyone, regardless of age, and the funds can be used for any purpose. SEPPs are payments that are calculated to exhaust the funds in your IRA (or combination of IRAs) over your life (or life expectancy), or over the joint lives (or joint life expectancy) of you and your beneficiary. To meet the SEPPs exception, you must use an IRS-approved distribution method, and take at least one distribution annually. There are three IRS-approved methods for calculating SEPPs, each of which requires you to select a life expectancy or mortality table, and two of which require that you select a reasonable interest rate.

Technical Note: The three IRS-approved methods for determining annual payments that qualify as SEPPs are the RMD method, the fixed amortization method, and the fixed annuitization method. The rules for calculating your SEPPs can be found in IRS Notice 89-25 and Revenue Ruling 2002-62.

If you have more than one IRA, you're not required to aggregate all of them in order to take advantage of the SEPPs exception. You can consider the account balance of only one of your IRAs, or you can elect to aggregate the account balances of two or more of your IRAs. But you can't use only a portion of an IRA to calculate your SEPPs. Because you're not required to aggregate all of your IRAs, you can use tax-free rollovers to ensure that the IRA that will be the source of your periodic payments contains the exact amount necessary to generate the specific payment amount you want. This makes the SEPPs exception a very important and flexible retirement income planning tool.

Even though your payments must be calculated as though they will be paid over your lifetime (or over your and your beneficiary's lifetimes), you don't actually have to take distributions for that long. You can change, or stop, your SEPPs after payments from your IRA have been made for at least five years, or after you reach age 59½, whichever is later. If you modify or stop the payments before then, you'll generally be subject to the 10% premature distribution tax on the taxable part of all payments you received before you reached age 59½ (unless the modification was due to death or disability). In addition, interest may be imposed.

Tip: The five-year period begins on the date of the first withdrawal, so no modification can be made before the fifth anniversary of that withdrawal. This is true even if you turn age 59½ before the fifth anniversary of that withdrawal.

Example(s): Assume John began taking annual distributions from his traditional IRA account three years ago, when he was 43 years old. (John has taken these distributions according to an IRS-approved method.) John does not take a distribution this year. Because John's payment stream has been "modified," the 10% penalty will now apply retroactively to all of his previous distributions, and interest may also be imposed. (A state tax penalty may apply, as well.)

Example(s): Assume that John began taking annual distributions from his traditional IRA on October 1, 2016, when he was 57½ years old. He also took the correct annual distributions in 2017, 2018, and 2019 (when he was age 60). Even though he was over age 59½ on October 1, 2019, he must take one more required distribution by October 1, 2020. Otherwise, he'll be subject to the 10% penalty on the taxable portion of the distributions he took when he was under age 59½.

Caution: To ensure that your distributions will qualify for the SEPPs exception to the premature distribution tax, get professional advice. The calculation of SEPPs can be complicated, and the tax penalties involved in the event of an error can be significant.

Should You Take Distributions From Your Traditional IRA Before Age 59½?

You are allowed to take distributions from your traditional IRA whenever you like and in any amount you choose. That does not mean, however, that you should. As a general rule, it is not advisable to take distributions from a traditional IRA before age 59½ (or for that matter, at any age prior to your retirement). First, as illustrated above, the portion of the distribution that goes to the federal government for taxes can be substantial — not to mention state taxes and penalties. This is especially true if the entire distribution is taxable, or if none of the exceptions to the premature distribution tax apply.

In addition, even if all or some of the distribution will not be taxed or penalized, taking IRA distributions before age 59½ may still be unwise. By dipping into your IRA funds at a relatively young age, you run the risk of depleting those funds sooner than you had anticipated. This could jeopardize your retirement goals and financial security later in life. Funds removed from an IRA may also be missing out on several years or more of potential tax-deferred growth, depending on investment performance.

However, the decision of whether to tap into your IRA nest egg ultimately depends on your individual circumstances. Perhaps you have urgent expenses, and withdrawing from your IRA is the only way you can pay them. It is also possible that you have accumulated large balances in your IRAs and other retirement accounts, so that withdrawing from your IRAs now will not pose a risk to your future financial security. In these cases, taking distributions before age 59½ is not necessarily ill-advised. Whatever your situation, though, you should consult a tax professional before taking a distribution.

Distributions from Traditional IRAs: Between Ages 59½ and 70½ (or 72)

Note: Recent legislation changed the general starting age for taking required minimum distributions (RMDs) from 70½ to 72 (if attain age 70½ after 2019).

Once you reach the age of 59½, you are allowed (but not required) to take distributions from your traditional IRA without being subject to the 10% premature distribution tax. You may choose to take distributions sporadically, as you need the money, or you may request an automatic distribution from your account according to a prearranged schedule you establish with your IRA administrator.

Should You Withdraw Money From Your IRA Between Ages 59½ And 70½ (Or 72)?

It depends on your circumstances. If you really need the money for income or unforeseen expenses, you might consider drawing on your IRA. However, if you have other sources of income and don't need the IRA funds, you may want to think twice about withdrawing funds. Even though you will be free of the premature distribution tax once you've reached age 59½, you still may have to pay income taxes on all or part of any IRA withdrawals (depending on whether or not the contributions you made were tax deductible). If the amount of a taxable distribution is substantial, it may even push you into a higher tax bracket for that year. This could increase your annual tax liability significantly.

In addition, if you take a number of large IRA distributions after reaching 59½, your IRA could be depleted (or at least reduced in size) more quickly than you had planned. This could mean a smaller nest egg for your later retirement years when you may need income the most, and a much smaller balance available to leave to your beneficiaries when you die. And, of course, the longer you leave funds in an IRA, the greater the opportunity for compounded, tax-deferred growth of earnings. The point is that it's generally not wise or appropriate to take distributions from an IRA between ages 59½ and 70½ (or age 72 if you attain age 70½ after 2019).

Distributions from Traditional IRAs: After Age 70½ (Or 72)

Ideally, you would like to have complete control over the timing of distributions from your traditional IRAs. Then you could leave your funds in your IRAs for as long as you wished, and withdraw the funds only if you really needed them. This would enable you to maximize the funds' tax-deferred growth in the IRA, and minimize your annual income tax liability. Unfortunately, it doesn't work this way. You must take what are known as required minimum distributions from your traditional IRAs.

What Are Required Minimum Distributions?

Required minimum distributions (RMDs), sometimes referred to as minimum required distributions (MRDs), are withdrawals that the federal government requires you to take annually from your traditional IRAs after you reach age 70½ (or age 72 if you attain age 70½ after 2019) . You can always withdraw more than the required minimum in any year if you wish, but if you withdraw less than required, you will be subject to a federal penalty tax. RMDs are calculated to dispose of your entire interest in the IRA over a specified period of time. The purpose of this federal rule is to ensure that people use their IRAs to fund their retirement, and not simply as a vehicle of wealth transfer and accumulation.

When Must RMDs Be Taken?

Your first RMD represents your distribution for the year in which you reach age 70½ (or age 72 if you attain age 70½ after 2019).

However, you have some flexibility in terms of when you actually have to take this first-year distribution. You can take it during the year you reach age 70½ (or age 72 if you attain age 70½ after 2019), or you can delay it until April 1 of the following year. Since your first distribution generally must be taken no later than April 1 following the year you reach age 70½ (or age 72 if you attain age 70½ after 2019), this date is known as your required beginning date (RBD). Required distributions for subsequent years must be taken no later than December 31 of each calendar year until you die or your balance is reduced to zero. This means that if you opt to delay your first distribution until the following year, you will be required to take two distributions during that year — your first-year required distribution and your second-year required distribution.

Example(s): You own a traditional IRA. Your 72th birthday is December 2 of year one (assume year one is 2021), so you will reach age 72 in year one. You can take your first RMD during year one, or you can delay it until April 1 of year two. If you choose to delay your first distribution until year two, you will have to take two required distributions during year two — one for year one and one for year two. That is because your required distribution for year two cannot be delayed until the following year.

Note: Required minimum distributions for IRAs and defined contribution plans (other than Section 457 plans for nongovernmental tax-exempt organizations) have generally been suspended for 2020. The waiver includes distributions for 2019 with an April 1, 2020, required beginning date that were not taken in 2019.

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Should You Delay Your First RMD?

Your first decision is when to take your first RMD. Remember, you have the option of delaying your first distribution until April 1 following the calendar year in which you reach age 70½ (or age 72 if you attain age 70½ after 2019). You might delay taking your first distribution if you expect to be in a lower income tax bracket in the following year, perhaps because you'll no longer be working or will have less income from other sources. However, if you wait until the following year to take your first distribution, your second distribution must be made on or by December 31 of that same year.

Receiving your first and second RMDs in the same year may not be in your best interest. Since this "double" distribution will increase your taxable income for the year, it may cause you to pay more in federal and state income taxes. It could even push you into a higher federal income tax bracket for the year. In addition, the increased income may cause you to lose the benefit of certain tax exemptions and deductions that might otherwise be available to you. So the decision of whether or not to delay your first required distribution can be crucial, and should be based on your personal tax situation.

Example(s): You are unmarried and reached age 70½ in 2018. You had taxable income of $25,000 in 2018 and expect to have $25,000 in taxable income in 2019. You have money in a traditional IRA and determined that your RMD from the IRA for 2018 was $50,000, and that your RMD for 2019 is $50,000 as well. You took your first RMD in 2018. The $50,000 was included in your income for 2018, which increased your taxable income to $75,000. At a marginal tax rate of 22%, federal income tax was approximately $12,440 for 2018 (assuming no other variables). In 2019, you take your second RMD. The $50,000 will be included in your income for 2019, increasing your taxable income to $75,000 and resulting in federal income tax of approximately $12,359. Total federal income tax for 2018 and 2019 will be $24,799.

Example(s): Now suppose you did not take your first RMD in 2018 but waited until 2019. In 2018, your taxable income was $25,000. At a marginal tax rate of 12%, your federal income tax was $2,810 for 2018. In 2019, you take both your first RMD ($50,000) and your second RMD ($50,000). These two $50,000 distributions will increase your taxable income in 2019 to $125,000, taxable at a marginal rate of 24%, resulting in federal income tax of approximately $24,175. Total federal income tax for 2018 and 2019 will be $26,985 - $2,186 more than if you had taken your first RMD in 2018.

How Are RMDs Calculated?

RMDs are calculated by dividing your traditional IRA account balance each year by the applicable distribution period. Your account balance is calculated as of December 31 of the year preceding the calendar year for which the distribution is required to be made. The applicable distribution period is generally the life expectancy factor for your age set out in the Uniform Lifetime Table published by the IRS. (If your beneficiary is your spouse, and he or she is more than 10 years younger than you, the applicable distribution period is determined using a joint and last survivor table published by the IRS.)

Caution: When calculating the RMD amount for your second distribution year, you base the calculation on your account balance in the IRA as of December 31 of the first distribution year (the year you reached age 70½ (or age 72 if you attain age 70½ after 2019)), regardless of whether or not you waited until April 1 of the following year to take your first required distribution.

Example(s): You have a traditional IRA. Your 72th birthday is November 1 of year one (assume year one is 2021), and you therefore reach age 72 in year one. Because you turn 72 in year one, you must take an RMD for year one from your IRA. This distribution (your first RMD) must be taken no later than April 1 of year two. In calculating this RMD, you must use the total value of your IRA as of December 31 of year one.

If you have more than one traditional IRA, a required distribution is calculated separately for each IRA. These amounts are then added together to determine your RMD for the year. You can withdraw your RMD from any one or more of your IRAs. (Your traditional IRA trustee or custodian must tell you how much you're required to take out each year, or offer to calculate it for you.)

Caution: Special rules apply if you have annuitized one or more of your IRAs.

What If You Fail to Take RMDs As Required?

If you fail to take at least your RMD amount for any year (or if you take it too late), you will be subject to a federal penalty tax. The penalty tax is a 50% excise tax on the amount by which the RMD exceeds distributions actually made to you during the taxable year. You report and pay the 50% tax on your federal income tax return for the calendar year in which the distribution shortfall occurs.

Example(s): You own a single traditional IRA and compute your RMD for year one to be $7,000. You take only $2,000 as a year-one distribution from the IRA by the date required. Since you are required to take at least $7,000 as a distribution but have taken only $2,000, your RMD exceeds the amount of your actual distribution by $5,000 ($7,000 - $2,000). You are therefore subject to an excise tax of $2,500 (50% of $5,000), reportable and payable on your year-one tax return.

Distributions from Roth IRAs

Qualified Distributions Are Completely Tax Free

You are free to make withdrawals at any time from your Roth IRA, but only qualified distributions receive tax-free treatment. A qualified distribution is not subject to federal income tax or a 10% premature distribution tax. A withdrawal from a Roth IRA (including both your contributions and investment earnings) is qualified if: (1) it is made at least five years after you first establish any Roth IRA, and (2) any one of the following also applies:

  • You have reached age 59½ by the time of the withdrawal
  • The withdrawal is made due to a qualifying disability
  • The withdrawal is made for first-time homebuyer expenses ($10,000 lifetime limit)
  • The withdrawal is made by your beneficiary or estate after your death

Tip: The five-year holding period begins on January 1 of the tax year for which you make your first regular contribution to any Roth IRA or, if earlier, January 1 of the tax year in which you make your first rollover contribution to any Roth IRA.

Tip: Because the five-year holding period runs from the first day of the plan year in which you establish any Roth IRA, you should establish one as soon as you can, even if you can afford only a minimal contribution. The earlier you satisfy the five-year holding period, the sooner you may be able to receive tax-free qualified distributions from your Roth IRA.

Nonqualified Withdrawals

Even if you make a withdrawal that fails to meet the requirements for a qualified distribution, your Roth IRA withdrawal enjoys special tax treatment. When you withdraw funds from your Roth IRA, distributions are treated as consisting of your contributions first and investment earnings last. Since amounts that represent your contributions have already been taxed, they are not taxed again or penalized (even if you are under age 59½) when you withdraw them. Only the portion of a nonqualified distribution that represents investment earnings will be taxed and possibly penalized. All of your Roth IRAs are aggregated when determining the taxable portion of your nonqualified distribution.

Example(s): In 2018, you establish your first Roth IRA and contribute $5,000 in after-tax dollars. You make no further contribution to the Roth IRA. In 2020 your Roth IRA has grown to $5,300. You withdraw the entire $5,300. Because you withdrew the funds within five tax years, your withdrawal does not meet the requirements for a qualified distribution. You already paid tax on the $5,000 you contributed, so that portion of your withdrawal is not taxed or penalized. However, the $300 that represents investment earnings is subject to tax and the 10% premature distribution tax, unless an exception applies.

Tip: Distributions from Roth IRAs are generally treated as being made from contributions first and earnings last (see ordering rules below). In the previous example, if you withdrew only $5,000 (leaving $300), the withdrawal would be tax free (and penalty free) since the entire amount would be considered a return of your contributions.

Technical Note: Technically, a distribution from a Roth IRA that is not a qualified distribution and is not rolled over to another Roth IRA is included in your gross income to the extent that the distribution, when added to the amount of any prior distributions (qualified or nonqualified) from any of your Roth IRAs, and reduced by the amount of those prior distributions that were previously included in your gross income, exceeds your contributions to all your Roth IRAs. For this purpose any amount distributed to you as a corrective distribution is treated as if it was never contributed.

Your Funds Can Stay In a Roth IRA Longer Than In a Traditional IRA

The IRS requires you to take annual RMDs from traditional IRAs beginning at age 70½ (or age 72 if you attain age 70½ after 2019). These withdrawals are calculated to dispose of all of the money in the traditional IRA over a given period of time. However,

Roth IRAs are not subject to the RMD rules. In fact, you are not required to take a single distribution from a Roth IRA during your life (although distributions are generally required after your death). This can be a significant advantage in terms of your estate planning.

Special Penalty Provisions May Apply to Withdrawals of Roth IRA Funds That Were Converted From a Traditional IRA

If you rolled over or converted funds from a traditional IRA to a Roth IRA, special rules apply. If you are under age 59½, any nonqualified withdrawal that you make from the Roth IRA within five years of the rollover or conversion may be subject to the 10% premature distribution tax (to the extent that the withdrawal consists of converted funds that were taxed at the time of conversion).

The reason for this special rule is to ensure that taxpayers don't convert funds from a traditional IRA solely to avoid the early distribution penalty.

Tip: The five-year holding period begins on January 1 of the tax year in which you convert the funds from the traditional IRA to the Roth IRA. When applying this special rule, a separate five-year holding period applies each time you convert funds from a traditional IRA to a Roth IRA.

Caution: This five-year period may not be the same as the five-year period used to determine whether your withdrawal is a qualified distribution.

Example(s): In 2017, you opened your first Roth IRA account by converting a $10,000 traditional IRA to a Roth IRA. You included $10,000 in your taxable income for 2017. You made no further contributions. In 2020, at age 55, your Roth IRA is worth $12,000, and you withdraw $10,000. The distribution is not a qualified distribution because five years have not elapsed from the date you first established a Roth IRA. And because you are making a nonqualified withdrawal within five years of your conversion, the entire $10,000 is subject to a 10% premature distribution tax, unless you qualify for an exception. This "recaptures" the early distribution tax you would have paid at the time of the conversion.

Example(s): You opened a regular Roth IRA account in 2013 with a contribution of $100, and made no further contributions to the account. In 2017, at age 60, you converted a $100,000 traditional IRA to a Roth IRA. In 2020, you withdraw $50,000 from this Roth IRA. Because you are over age 59½ in 2020, and because more than five years have elapsed from January 1, 2013 (the year you first established any Roth IRA), your withdrawal is a qualified distribution and is totally free of federal income taxes. Even though your withdrawal was within five years of the conversion, no penalty tax applies.

Which Assets Should You Draw From First?

You may have assets in accounts that are taxable (e.g., CDs, mutual funds), tax deferred (e.g., traditional IRAs and 401(k)s), and tax free (e.g., Roth IRAs and Roth 401(k)s). Given a choice, which type of account should you withdraw from first? The answer is — it depends.

For retirees who don't care about leaving an estate to beneficiaries, the answer is simple in theory: withdraw money from taxable accounts first, then tax-deferred accounts, and lastly, tax-free accounts. By using your tax-favored accounts last, and avoiding taxes as long as possible, you'll keep more of your retirement dollars working for you.

For retirees who intend to leave assets to beneficiaries, the analysis is more complicated. You need to coordinate your retirement planning with your estate plan. For example, if you have appreciated or rapidly appreciating assets, it may be more advantageous for you to withdraw from tax-deferred and tax-free accounts first. This is because these accounts will not receive a step up in basis at your death.

However, this may not always be the best strategy. For example, if you intend to leave your entire estate to your spouse, it may make sense to withdraw from taxable accounts first. This is because spouses are given preferential tax treatment with regard to retirement plans. A surviving spouse can roll over retirement plan funds to his or her own IRA or retirement plan, or, in some cases, may continue the deceased spouse's plan as his or her own. The funds in the plan continue to grow tax deferred, and distributions need not begin until the spouse's own required beginning date.

Another factor to consider is that IRA assets enjoy special protection from creditors under federal and most state laws. Federal law provides protection for up to $1,362,800 (scheduled for adjustment in April 2022) of your aggregate Roth and traditional IRA assets if you declare bankruptcy. (SEP IRAs, SIMPLE IRAs, and amounts rolled over to the IRA from an employer qualified plan or 403(b) plan, plus any earnings on the rollover, aren't subject to this dollar cap and are fully protected if you declare bankruptcy.)

The laws of your particular state may provide additional bankruptcy protection, and may provide protection from the claims of your creditors even in cases outside of bankruptcy. IRAs you've inherited may be afforded less protection under state and federal law. You should check with an attorney to find out how your state treats IRAs. If asset protection is important to you, this could impact the order in which you take distributions from your various retirement and taxable accounts. The bottom line is that this decision is a complicated one. A financial professional can help you determine the best course based on your individual circumstances.

 

 

This material was prepared by Broadridge Investor Communication Solutions, Inc., and does not necessarily represent the views of  The Retirement Group or FSC Financial Corp. This information should not be construed as investment advice. Neither the named Representatives nor Broker/Dealer gives tax or legal advice. All information is believed to be from reliable sources; however, we make no representation as to its completeness or accuracy. The publisher is not engaged in rendering legal, accounting or other professional services. If other expert assistance is needed, the reader is advised to engage the services of a competent professional. Please consult your Financial Advisor for further information or call 800-900-5867.

 

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The Retirement Group is a Registered Investment Advisor not affiliated with FSC Securities and may be reached at www.theretirementgroup.com.

 

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