*April 16th, 2002 and again on October 3rd, 2002 the IRS finalized rule changes that affected 72(t) distributions. This calculator incorporates the new regulations, many of which are describe in detail below. For more information regarding these changes please see Revenue Ruling 2002-62 on www.treasury.gov.
- Substantially Equal Periodic Payments (SEPP)
- The rules for 72(t) distributions require you to receive Substantially Equal Periodic Payments (SEPP) based on your life expectancy to avoid a 10% tax penalty on any amounts your withdraw. 72(t) payments must last for five years or until you are 59 1/2, whichever is longer. Further, the SEPP amount must be calculated using one of the IRS approved methods which include:
In addition, October 3, 2002 the IRS ruled that you could change your distribution type one time without penalty from the Annuitized or Amortized methods to the Life Expectancy method. This would allow account holders the option to move from a fixed payment type to a payment that fluctuates annually with the value of their account. The primary reason for this exception is to allow individuals who have suffered large losses the option to reduce their distribution to prevent their retirement account from being prematurely depleted. For more information on this important exception please see Revenue Ruling 2002-62 on www.treasury.gov.
It is important to remember that while 72(t) distributions are not subject to the 10% penalty for early withdrawal, all applicable taxes on the distributions must still be paid. Further, taking any early distributions from a retirement account reduces the amount of money available later during your retirement.
- Account balance
- The account balance used to determine the payment must be determined in a reasonable manner. For example, a first distribution taken on July 15, 2003 it would be reasonable to determine the account balance based on the value of the IRA from December 31, 2002 to July 15, 2003. For subsequent years the same valuation date should be used.
- Your age
- This is your current age. Use the age you will turn on your birthday for the year you are receiving the distribution.
- Beneficiary age
- This is your beneficiary's age. Use the age your beneficiary will turn on their birthday for the year you are receiving the distribution. This entry is ignored if you do not use your Joint Life Expectancy to calculate your SEPP.
- Life expectancy tables
- There are three different life expectancy tables that the IRS allows you to use when calculating your SEPP with the "Fixed Amortization" or the "Required Minimum Distribution" methods. It is important to note that once you have chosen a distribution method and life expectancy table, you cannot change either throughout the course of your distributions. (Except for a one-time change from the Annuitized or Amortized methods to the Life Expectancy method, see SEPP definition for more details). The three life expectancy options are:
| Table | Description |
| Single Life Expectancy | This is a non-sex based life expectancy table. This table does not use your beneficiary's age to calculate your life expectancy. This table can be used by all account owners regardless of marital status or selected beneficiary. Choosing single life expectancy will produce the highest distribution of the three available life expectancy tables. |
| Joint Life Expectancy | This is also a non-sex based life expectancy table for determining joint survivorship using your oldest named beneficiary. |
| Uniform Lifetime | This is a non-sex based table developed by the IRS to simplify minimum distribution requirements. The uniform lifetime table estimates joint survivorship, but does not use your beneficiary's age to determine the resulting life expectancy. This table can be used by all account owners regardless of marital status or selected beneficiary. |
- Reasonable interest rate
- This is any rate less than the 120% of the current Federal Mid-Term interest rate. It is important to note that the associated law that created the 72(t) distributions did not define what was to be considered a reasonable interest rate. As such, the guidance from the IRS generally flows from concept that they will not allow people to circumvent the requirement of substantially equal periodic payments throughout your lifetime by using an unreasonably high interest rate.
72(t) withdrawals setup prior to January 2003 had some flexibility in the choice of the reasonable rate to use. However, in 2002, the IRS issued new rules stating that only rates under 120% of the Federal Mid-Term rate would be considered reasonable. For example, in January 2003 the Mid-Term Federal rate was 3.43%. This means any interest rate under 4.12%, which is 120% of 3.43%, is acceptable. This is a change from the 1989 IRS ruling where it was acceptable to use an interest rate tied to the average Federal Long-Term rate. Since Federal Mid-Term rates are usually lower than Federal Long-Term rates, the affect has been a net reduction in the distribution amount that can be withdrawn.
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