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Hello

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  1. Considering your audience, it's cruel not to provide the details. Darn ethics.
  2. For IRRs: Under age 59½, 10% penalty waived. RECAPTURE TAX - The 10% will be applied if the IRR conversion is withdrawn before five years. • Recapture tax will not apply if: – Attainment of age 59½ – Distribution due to severance from service in year age 55 attained or later – A known exception to the penalty occurs Measuring Five-Taxable-Year Recapture Period • Recapture tax’s five-taxable-year period – Starts with the first day of participant’s tax year in which in-plan Roth conversion made, usually January 1 – Ends on last day of individual’s fifth taxable year after conversion – Amounts may be rolled to another Roth without penalty. If withdrawn from subsequent Roth before end of five-year period, 10% recapture tax will apply. • A separate designated Roth sub-account should be established for each in-plan Roth conversion in order to appropriately apply the recapture tax or acceleration of income rules.
  3. I saw this on a plan like 20 years ago. Check to ensure that the distribution options are the same for the money sources. If in-service distributions (or hardships, etc.) are only permitted from salary deferrals, repaying the loan to the profit-sharing bucket will impact that.
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