RestAssured Posted June 17, 2020 Share Posted June 17, 2020 If someone under the age of 59.5 wishes to take a withdrawal based on the CARES Act, are they still restricted on money type(s)? In other words, can they withdraw their Safe Harbor money? I haven't had anyone ask for a withdrawal until now, surprisingly. And I have searched for an answer, and can't find it. I swear I've read this somewhere, so forgive me if it's been answered. Thanks! Link to comment Share on other sites More sharing options...
Peter Gulia Posted June 17, 2020 Share Posted June 17, 2020 If a plan provides any coronavirus-related distribution, whether the plan restricts it to an elective-deferrals subaccount or allows it from other subaccounts is the plan sponsor's decision. Luke Bailey and hr for me 2 Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com Link to comment Share on other sites More sharing options...
Ellie Lowder Posted June 22, 2020 Share Posted June 22, 2020 In the situation where the plan does not permit a COVID distribution, but the participant can take one and properly report it, can the participant take it from an account other than the elective deferral account? Link to comment Share on other sites More sharing options...
Peter Gulia Posted June 22, 2020 Share Posted June 22, 2020 That a distribution is attributable to a subaccount other than the distributee’s elective-deferral subaccount does not make it one a distributee could not on her tax return treat as a coronavirus-related distribution if it otherwise meets those conditions. Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com Link to comment Share on other sites More sharing options...
Mike Preston Posted June 22, 2020 Share Posted June 22, 2020 1 minute ago, Peter Gulia said: That a distribution is attributable to a subaccount other than the distributee’s elective-deferral subaccount does not make it one a distributee could not on her tax return treat as a coronavirus-related distribution if it otherwise meets those conditions. Very close to a triple negative. Link to comment Share on other sites More sharing options...
Peter Gulia Posted June 22, 2020 Share Posted June 22, 2020 Yes; but it fits the assumptions embedded in Ellie's query. Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com Link to comment Share on other sites More sharing options...
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