The Youngest Person to do Reg 72(t)/SEPP Plan

***The following is not intended as advice.  You should seek a professional familiar with your circumstances and familiar with Reg 72(t)/SEPP for help.  There are not many financial advisors/professionals/CFP actually familiar with Reg 72(t).  Check my services tab if you need help with Reg 72(t) and we can talk.  This is a 72(t) plan based on my situation, which is different from yours.  Screwing up your calculation or making a mistake by even 1 penny, can bust your plan and have serious tax consequences.  Again this is not advice for you.  I only help people with this topic for a fee.  All spreadsheets are only applicable to my situation, your variables and numbers will be different from mine.  DO NOT USE THESE SPREADSHEETS FOR YOUR OWN 72(t) Calculation***

Have you ever thought “Man, I’ve socked away a bunch of money in my 401(k) plan and wish I could retire early, but the IRS will hit me with a 10% early withdrawal penalty since I’m not 59.5 years old.”  What if I said there was a completely legal way to avoid that 10% penalty, so you could retire early.  You know, since you actually did what few people actually do- max out that 401(k) and invest smart.  After all, why should you be penalized, just because most people lack financial discipline.

Well, congrats on finding my site.  This is where you want to become familiar with internal revenue code Reg 72(t), otherwise known as Substantially Equal Periodic Payments.  Basically, the rules under Reg 72(t)/SEPP allow for a person to withdraw money from their IRA, prior to turning age 59.5 years of age, and not have to pay that 10% penalty.  It is one of the few exceptions to the 10% early distribution penalty.  The catch is, there are rules you have to follow.  Also, SEPP is not for someone lacking in financial discipline.

Let me also say, I was first introduced to Reg 72(t) back in 2001.  At the time I was working in a small investment office.  One of the managers clients worked at AT&T all of his life and was ready to retire at the age of 53.  That moment had a huge impact on me, seeing that you didn’t have to work all your life, but it also started my introduction into SEPP.  I continued to learn more about it over the years, only to ultimately find out, not many people in the financial services industry REALLY understand it.  That can be dangerous for you as a client.

You should really read my most visited page for more details on Reg 72(t).  I’ll cut and paste a few things here, before going over my plan.

So what’s the big freakin’ deal about Reg 72(t) distributions and why isn’t anyone ever talking about it?  For anyone doing a withdrawal from a Traditional IRA prior to age 59.5 years of age, you will be faced with ordinary income taxes on the amount withdrawn for the year, but also a 10% early distribution penalty (unless you qualify for an exception-most are tied to bad things happening to you though).  Pretty steep penalty to access your money early.  Reg 72(t) doesn’t get talked about much, because it honestly isn’t very well understood or even know about by many investors or professionals.

So the big deal? Reg 72(t) allows for someone to take distributions from their IRA (following certain rules)and avoid having to pay the 10% penalty (you still have to pay ordinary income taxes on the withdrawal-no work around there).   The distributions have to be “part of a series of substantially equal periodic payments” (you may see SEPP used-not to be confused with SEP IRA) made at least annually for the life expectancy of the individual (or joint life if applicable).  72(t) distributions must continue for the greater of either 5 years or attaining age 59.5.  Any misstep or wrong calculation can subject ALL years of distributions t0 be penalized at 10% plus interest owed to the IRS (now you see why it’s important to work with someone that actually knows this stuff).

There are 3 methods to determine SEPP:

Life Expectancy Method– basically using the minimum distribution rules, but before age 70.5, distribution amounts change annually

Amortization Method– Amortize account balance using a life expectancy and a reasonable interest rate (reasonable interest rate is defined by the IRS as not more than the 120% Federal Mid Term Rate for either of the 2 months prior to the first distribution), distributions stay the same

Annuitization Method– account balance divided by a life expectancy factor and interest rate, distribution amount stays the same

So basically, 72(t) allows for an early retiree to access their IRA prior to age 59.5 and avoid the 10% penalty tax.  For early retirees this is huge.  For most normal people, their biggest “asset” is their house, followed by their 401(k), then everything else.  For someone retiring at say age 36 (that age sounds familiar), you would be able to rollover your 401(k) to a traditional ira, establish your 72(t) distributions on that IRA, use your dividends from your brokerage account, and enjoy retirement.  If 72(t) didn’t exist, you would have to have a bunch of money built up in individual accounts to retire early and you would have to wait until age 59.5 to touch your IRA.  No beuno.

Like most things in life, there are pros and cons to 72(t) distributions:

PROS:

-Access to your IRA prior to age 59.5 so you can retire early without the 10% penalty

-The actual calculations are not that complicated

-You can divide your IRA into multiple IRA accounts, and do a 72(t) on just one of the balances (if you are looking to receive a particular dollar amount).  This gives some flexibility for longer term planning taking into consideration COLA

-You have a one time chance to change from Amortization/Annuitization Methods over to the Life expectancy method (good because as your IRA balance grows over time, you can basically recalculate your 72(t) payment going forward)

-You can go back to work (full/part time) after starting a SEPP.  You still have to take the 72(t) distributions however.

CONS:

-If you screw something up on your withdrawals, the penalty can be substantial (referred to as busting the plan)

-Takes solid financial dedication to execute (this plan is not for spend thrifts).  It’s kinda like poker “minutes to learn, a life time to master”

-Depending on your lifestyle, may not provide enough income to live off (you would want brokerage investments  or side hustle for added income and flexibility)

-No flexibility of distributions (hence Equal Periodic Payment)

A side note:  If you are 55 years or older and separated from service, you will want to check with your 401(k) plan provider about penalty free distributions without the hoops to jump through of a 72(t).  This demographic is probably the last group that should look at a rollover and 72(t) distribution.  However advisors do it for the commission.  Unfortunately, not all plans allow this provision, but it is worth calling your plan provider.

Another note: There is also a funny provision.  If your SEPP IRA runs out of money, say an investment went south, this is not considered a modification to that plan and does not bust the plan, so no 10% penalty tax is assessed.

Last note: (mentioned above) You can do a one time change from Amortization or Annuitization method over to the Life Expectancy method.

Once you establish a Reg 72(t)/SEPP plan, you DO NOT want to add funds to that particular account.  This means either by rollover or just regular contribution.  Doing so, is considered a modification of your plan and will subject you to penalties and interest.

Also, just because you’ve established a SEPP, doesn’t prevent you from going back to work.  So if a good opportunity arises, you can take the work.  You still want to continue as normal with your 72(t) distributions/SEPP, otherwise not taking the withdrawals will subject you to penalty and interest.

Let’s look at my Reg 72(t)/SEPP plan

We’ll look at my actual calculation, future projected cash flows, and point out some tips and why I have chosen to go the route I did.  Also, as far as I know, I am the youngest person to implement a 72(t) plan.  I started technically at age 36 (the plan however is effectively age 37-my age by the end of the year).

A couple of things to think about.  You can split a traditional IRA into multiple accounts.  This allows a person to set up a SEPP on just one account, leaving the other IRA accounts alone to grow and maybe do a separate SEPP on the other IRA down the road.

Let’s get into the calculation.  IT IS IMPORTANT THAT YOU KEEP VERY GOOD RECORDS OF EVERYTHING WHEN DOING A 72(t) CALCULATION.  I can’t emphasize that enough.  You want the records in case of an audit, also most agents at the IRS have no clue about Reg 72(t), making it more important to back up your work.  I’m focusing on the Amortization method.  The calculation is relatively easy.  You are basically amortizing an account balance, over your life expectancy, using an appropriate interest rate that is no greater than the 120% Mid Term Rate.  You can look into amortization formulas, but when you look at it, you’ll probably say “fuck it, I don’t remember my order of operations for math”. HINT: PEMDAS-please excuse my dear aunt sally.

So there is a simple way to figure it out.  You want to document your account balance that you are using, so saving a copy of the month end statement is very important.  I set up my 72(t) for the month of September in 2016.  So I used the month end balance of August.  All of my paperwork and calculations are nicely organized and tucked away for safe keeping.  The appropriate 120% Mid Term Rate at the time was no more than 1.71%, so I used 1.71%.  My life expectancy as a single male (turning age 37 by year end) is 46.5 years.  Life expectancy figures are found in Pub 590.  Plugging these variables into Excel:

***The Below Spreadsheet is NOT to be used for your 72(t) calculation.  It may not apply in your situation, and your variables are almost certainly different.  I am not liable for any mistakes you make.  Consult a professional.  See top of post for additional info***

So, in calculating my 72(t) distribution, we see that I am having to pull $10,829.03 from this IRA each year until I hit age 59.5.  Since this is my first year and I didn’t really need the funds, I opted to not take the full amount out.  In the first year of a SEPP, you can treat it as a stub year and pro-rate the withdrawal.  In this case, I am taking 4/12ths which works out to $3609.68 in year 1.

A little insight into why I went ahead and set up my plan the way I did.  I could have created a SEPP with a bigger dollar amount, or waited until 2017 or later.  I could have used a lower rate in my calculation.  The reason for setting up the plan and with that dollar amount, simply because the account triggers dividends that are higher than my required withdrawal.  Basically, I am not even taking out all of the dividends from that SEPP IRA (remember this, I’ll circle back to it a little later).

The second reason is taxes.  I’m normally one to say “don’t let taxes be the reason behind making an investment.”  You invest to make money.  You don’t invest just for tax benefits.  Hell, you can lose money on a stock investment and get a tax write off, personally I prefer making money and paying taxes on gains.  In this case, it’s a little different for me.  Look at the current tax brackets for singles in 2016:

Bracket: 10% = $0-$9275

Bracket: 15%= $9276-$37,650

That income places me just in the 15% tax bracket.  Factoring in the standard deduction ($6300) and personal exemption ($4050), I will pay next to nothing in federal income taxes.  State income taxes will also be negligible.  Essentially, I am able to pull it out tax free/near tax free.  My effective tax rate will be stupidly low.  Also, as time goes by and the tax brackets (and standard deduction and personal exemption) are slowly adjusted for inflation, I will eventually drop into the 10% bracket.  The other kicker, since my ordinary income is so low, my qualified dividend income from my brokerage account is tax free.  You read that right.  My qualified brokerage account dividends almost equal the dividends from this SEPP IRA.  This works for someone in the 10 or 15% tax brackets.  Granted, I am just reinvesting the dividends from the brokerage account at this moment (purchasing additional tax free and growing future dividend income).  Staying in the 10 or 15% tax bracket, also allows me to pay 0% capital gains on the sale of stock in my brokerage account (should I choose to sell something).  Thanks government.

The final reason is real simple to understand…it’s enough income for me to live off of and have a little extra disposable income each month for fun.  I have a real simple debt free life.  That income from the SEPP covers my cost of living, fun money, and I still have extra each month that finds it’s way back into other brokerage investments (purchasing basically additional tax free and growing qualified dividends-it’s a glorious viscous cycle).  If I need anything extra for spending, I can just stop reinvesting my dividends in my brokerage account and take that money out.  But also, I can choose later in life to set up another SEPP IRA down the road with other IRA accounts.

Here are some figures I plotted out in excel.  I ran figures going until the year I hit age 59.5 (also turn 60 in 2039).  It compares income from my SEPP Plan and brokerage account Dividends vs Expenses.  In these tables I am holding my SEPP income constant, not taking into account any one time change.  Dividend Income is growing at a 5% rate and expenses are increasing at 4% per year.  There are tabs at the bottom for charts.

Why did I chose the Amortization Method for my 72(t) distribution?

Well, look just above at the 3 reasons.

Another reason, the amortization method provides the higher dollar amount for me.  Calculation using the life expectancy method is actually super simple.  Account balance divided by life expectancy factor.  Life expectancy provides a lower amount and you have to recalculate it each year.  Your cash flows will vary each year.

Knowing that the dividend income inside of that portfolio is very stable, highly predictable, and slowly growing, I thought it makes cense in my situation to pull the higher amount-hence amortization method.  I don’t want to short change myself by doing to small of a withdrawal rate.

Another reason for me choosing Amortization over Life Expectancy: under Reg 72(t), you are allowed to make a 1 time modification by switching from the Amortization or Annuitization Method over to the Life Expectancy Method.  It gives me an option to make a one time change down the road.  So the defense of this reasoning is: I expect the account balance to grow over time (we are not talking about the dividend growth here-just straight up capital appreciation).  Lets say in 10 or 15 years, the balance on this account is to double to say $700,000.  At that time, I may decide to switch over to the Life Expectancy method, bumping up my 72(t) withdrawal to a little over $19,000 for that year.  That is almost double where I started with the plan.  If I stay in just the Amortization Method, I am still just drawing out the $10,829.03, while the account balance is double (and most likely the dividend income has doubled).  I don’t want to live a deprived life, it’s why you work hard and hustle early in life to get to this point.  If I were to switch to Life Expectancy Method down the road, the income would change from year to year.  The balances/income in my other accounts should have respectably grown at the time, providing stable income if I need it, allowing more room for the 72(t) to vary from year to year.  So starting Amortization leaves the option open for going to the Life Expectancy method later in life and potentially increase the amount I withdraw later on.  This is important for someone younger setting up a 72(t) plan.

Lets chart out what I’m talking about here:

The above chart has a lot of moving pieces to it.  Basically I am pulling out what I need, have a safety cushion with my brokerage account.  In between now and 10 years down the road, as the dividends in this SEPP IRA grow slowly, I am reinvesting the excess over the SEPP amount.  Around age 47, I switch over to the life expectancy method.  This increases my SEPP income from the higher balance (also my brokerage account dividends are higher too).  Somewhere around age 52/53 (possibly later) that is when I actually start dipping into principal on the SEPP IRA for a few years.  When I hit age 59.5, I stop this whole plan entirely, and can pull whatever I want out.  These are just projections.  When the time nears, is when I’ll have to decide if I make a one time switch to the Life Expectancy methods.  Things that could make a difference: getting married, tax brackets, health.  I don’t have to worry about that things right now, but I may be married some day, taxes I have no control over what congress does-but as the rules are now it’s worth playing to my favor, and eventually I should be more concerned about my health even though I am perfectly fine right now.  Keep in mind, these figures don’t even account for other IRA or Roth IRA balances.

Lastly, either way you look at it, the dollar amount is not that great.  According to the government I am living below the poverty level (a debt free life allows you to comfortably pull this off).  Many other finance bloggers have families and live on an income per family member ratio of less than me.  If I were to go back to work (should an appropriate opportunity arise), I’m not doing anything that will trigger massive amounts of taxes.  If I work a year or 2, and decide to enter early retirement #2, I already have my plan in place and just go back to an almost income tax free lifestyle.

Keeping Track of Everything

I can’t emphasize enough, how important it is to work with someone who knows Reg 72(t).  You ultimately are responsible for your own plan, so keeping good records is very important.

To make sure I don’t forget a withdrawal and take out enough each year, here is a simple tracker that I’ve built.  It shows when I’ve taken money out and if I am at a shortfall for the year.

I also provide customers with a document detailing their withdrawal plan.  It has information such as start date, Interest rate, method used, etc.  It is also a good idea to keep a digital and physical copy of a statement reflecting the balance used for the plan.

Why is keeping track of everything so important?  Well, I stated earlier, most IRS agents don’t even know much about Reg72(t).  So in case of an audit, you have all the info needed to school the agent.

Also, it’s important to have good records because causing an error, such as taking out too much or too little in a year, can be a costly mistake.  You will have busted your plan.  Busting your plan is expensive the later on it takes place.  You have to pay the 10% penalty on ALL withdrawals and retroactive interest.  Good luck finding an account that can actually figure this out for cheap.  As an example, if I screw something up in my last year, I would have a total of a little over $31,000 due in penalties and interest.  So you definitely don’t want to make a mistake.

72(t) Plans/SEPP is not appropriate for a lot of people.  Anyone who is too loose with their money, really need not apply.  For those interested in FIRE (financial independence retire early), it really is a great way to tap into a big pool of assets and avoid paying that pesky 10% early distribution penalty.  With careful planning, you can make it so you pay very little in taxes in early retirement, and also enjoy the benefit of 0% federal taxes on dividends and capital gains for those who are able to stay in the 10-15% tax brackets under todays current tax rules.  Remember, there are specific rules to follow.  It’s not a bad idea to have a separate IRA balance for down the road (to set up a SEPP if needed), and it definitely doesn’t hurt to have other assets (rental income, brokerage investments, side income) to provide flexibility down the road.  Also, having a budget and tracking expenses never hurt anyone.

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  1. How I Pay No Taxes in Early Retirement – BAMF Money.com
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