SECURE Act Proposed Regulations Impact 10 Year Distribution Rule Bigly!

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One of the biggest changes made by the SECURE Act was the imposition of a 10 year distribution rule for certain IRA (and other defined contribution-type retirement account) beneficiaries. This 10 year rule applies when the account owner dies after December 31, 2019. Under the new 10 year rule, most non-spouse beneficiaries must withdraw the entire balance of an inherited retirement account within 10 years of the year of the account owner’s death.

(If the account owner died before January 1, 2020, the old lifetime distribution rules still apply and allow a beneficiary to take distributions from an inherited IRA over the beneficiary’s remaining life expectancy.)

The 10 year rule itself seems straightforward. When the rule was enacted, commentators and practitioners (myself included) believed that the account beneficiary had the choice to delay liquidating the balance of the inherited IRA until the end of the 10th anniversary year, or take distributions at any time during the 10 year distribution period as long as the entire account balance was distributed before the end of that 10th year.

However, the proposed regulations introduce a significant wrinkle that will impact a great number of IRA beneficiaries who are subject to the 10 year distribution rule. Under the proposed regulations, the account beneficiary must take required minimum distributions (RMDs) from the inherited IRA during the 10 year period if the account owner died on or after their required beginning date (RBD). In other words, if the account owner was subject to RMDs at the time of his death, then the designated account beneficiary must take an annual distribution from the inherited account beginning in the year following the account owner’s death. The amount of the annual RMD will be calculated using the beneficiary’s remaining life expectancy, reduced by one for each subsequent calendar year during the 10 year term, with the remaining balance withdrawn before the end of that 10th anniversary year.

If the IRA owner died before his RBD, then the account beneficiary will be subject to only the 10 year distribution rule, but not the additional RMD rules.

In sum, if the IRA owner dies before his RBD, the beneficiary has 10 years from the year of the account owner’s death to liquidate the entire balance in the inherited IRA. If the IRA owner dies after his RBD, the beneficiary likewise has 10 years from the year of the account owner’s death to liquidate the entire balance in the inherited IRA, but must also take an annual RMD from the account during the 10 year term.

Let’s look at a couple of examples:

Death before RBD: John is the 30 year old son of IRA owner William. John is the beneficiary of William’s IRA. William dies in August 2022 at the age of 55. Since William died before his RBD (April 1 following the year William would have reached age 72), John is subject to the 10 year liquidation rule and must simply withdraw the entire balance of William’s IRA before December 31, 2032, the 10th year following William’s death.

Death after RBD: In this example, IRA owner William dies in August 2022 at the age of 73. John, William’s 50 year old son is William’s beneficiary. Since William died after his RBD (April 1 of the year following the year William turned age 72), John is subject to both the 10 year liquidation rule, and the RMD rules. So beginning in 2023 John must calculate a required minimum distribution based upon his remaining life expectancy for years 1 through 9 of the 10 year term, withdrawing the entire remaining balance by the end of year 10.

But what about Roth IRA beneficiaries you ask? The proposed regulations confirm that all Roth IRA owners are deemed to have died before their required beginning date (because Roth IRA owners are exempt from required minimum distribution rules). Therefore, if a Roth IRA owner dies after December 31, 2019, her account beneficiary will only be subject to the 10 year distribution rule. This will allow for an additional 10 years of tax free growth before a distribution needs to be taken.

The rules governing distributions from IRAs and other retirement accounts have always been complex. The proposed regulations if and when adopted will only add to the complexity. You should work with an qualified advisor who can help you avoid all of the potential tax traps that await the unwary.

If you are not sure how the rules may apply to your situation, give us a call, we can help.

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[This article is for informational purposes only. It is not legal or tax advice, and does not create or continue an attorney-client relationship.]

Wash Away Debt in Bankruptcy and Keep Your IRA? Yes, You Can Do It.

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Financial planning isn’t always about champagne dreams and caviar wishes. For many, it is simply about not drowning in debts after retirement.

I recently met with a client to discuss her options dealing with significant credit card debt. She is nearing retirement and did not know how she could make ends meet on a fixed income. She was hesitant to file bankruptcy because she was afraid she would lose her IRA to creditors if she did.

Like my client, many people avoid bankruptcy because they fear losing their IRA in the process. But it is almost always a bad idea to tap IRA money to pay debts. The IRS will assess a 10%penalty and income taxes on the withdrawn money if you are not yet age 59 ½. Also, you may find yourself running short of funds later in retirement when you will likely need the money.

Michigan and federal bankruptcy law offer IRA protection from creditors in bankruptcy. A bankruptcy filer in Michigan may use either state or federal exemptions to protect an IRA while getting rid of debts.

Under Michigan law, you may protect all traditional and Roth IRAs accounts in bankruptcy, including payments or distributions from those accounts or annuities. The Michigan exemption does not extend to money contributed to the IRA made within 120 days before filing bankruptcy. Second, the exemption does not protect IRAs from an order of a domestic relations court (spousal or child support). Finally, the exemption does not protect nondeductible contributions to an IRA or annuity contract.

The United States Bankruptcy Code protects traditional and Roth IRAs accounts to a combined limit of $1,362,800 (inflation adjusted). You can have any number of accounts of any type as long as the combined total of all such accounts does not exceed the exemption limit.

If the IRA consists of funds rolled over from an employer sponsored account, such as a 401(k) or 403(b), the dollar limit does not apply. The rollover funds will retain the unlimited protection under federal law.

The federal IRA exemption would work better for my client. Her IRA isn’t that large, and the federal exemptions for her other assets are more attractive than the Michigan exemptions.

You must consider many factors in making a decision to file bankruptcy. If you are at the point where you are considering an IRA withdrawal to pay down debts, bankruptcy may be the better option.

If you are struggling with debt and looking for a solution, give us a call, I can help you.

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Skinning a Cat – Company Stock in a 401k Plan

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I often work with clients on the cusp of retirement who hold company stock in their employer-sponsored 401k accounts. The client wants to move the account balance to an IRA, but isn’t sure what to do with the company stock and the plan administrator is of little help.

The IRS permits tax-free rollovers of company stock to an IRA. When the company stock is later distributed from the IRA, the stock is taxed at ordinary income tax rates based on the stock’s fair market value on the date of distribution. That fair market value then becomes the basis for computing capital gains or losses on the future sale of the stock.

This strategy often presents a tax problem for the employee. The stock’s value may have appreciated considerably since acquired in the 401k. The employee faces the loss of capital gain treatment on the stock sale when distributed from an IRA post-rollover. Selling the stock inside the IRA doesn’t offer any benefit either, because the proceeds will be taxed as ordinary income when distributed from the IRA.

However, it may make sense to distribute all of the company stock from a 401k instead of moving it to an IRA.

This move offers a couple of strategies that can work to reduce any tax bite to manageable levels. The first strategy, which we’ll discuss in this post, is to take advantage of net unrealized appreciation (NUA) treatment on a distribution of company stock from a 401k.

NUA treatment allows the employee to take company stock from a 401k and pay ordinary income tax on the original cost of the stock (basis), rather its fair market value when distributed. The difference in the stock’s basis and its fair market value at distribution is the NUA. The NUA is not taxed when the stock is distributed provided the employee removes ALL of the employer stock from the 401k. The tax on the NUA can be deferred until the stock is sold, and the NUA (along with any post-distribution gain) is taxed as long term capital gain. (Capital gains tax rates range from 0 to 15% to 20%.) And, the long term capital gain on the NUA is not subject to the extra 3.8% tax on net investment income.

To qualify for NUA treatment, the company stock must be the stock of your employer. So, if you work for Apple, you can’t get NUA treatment for Amazon stock held in your 401k. The distribution must be a lump sum of the entire 401k account balance taken in one tax year. The distribution must occur after a qualifying event such as separation from service, reaching age 59½, death, or disability. The balance of the plan assets (non-company stock, etc.) can be rolled over tax free to a traditional IRA or another company plan.

Dealing with company stock in an employer plan account is never easy. You must consider many factors before making a decision. There are tax traps to avoid. Make sure you are working with a knowledgeable advisor when considering which option is best.

In my next post, we’ll look at the other strategy available to deal with company stock in a qualified plan account. Until then, if you are confused about handling a retirement plan distribution or rollover, give me a call, I can help.

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Contending With Accelerated Distributions Under The SECURE Act – Disclaimers

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By now, most of you are aware of the massive changes made by the SECURE Act to the IRA distribution rules. These new rules affect the beneficiaries of IRAs or other tax deferred retirement accounts whose owners die after December 31, 2019. Under the new rules, most non-spouse beneficiaries must completely liquidate an inherited IRA or other tax deferred retirement account by the end of the 10th year following the year of the account owner’s death.

The new rules do not mandate periodic distributions for those subject to the 10 year rule, merely a complete liquidation by the deadline. Many IRA beneficiaries will likely incur substantially larger tax bills due to the bunching of IRA distributions into this compressed time frame. However, a beneficiary may avoid those anticipated tax liabilities by disclaiming her rights in the inherited IRA.

A disclaimer is the refusal to take possession, or enjoy the benefit of an IRA belonging to a deceased person. It’s a legal “no thank you.” A beneficiary may disclaim all or a part of the IRA.

Done correctly, a disclaimer permits an IRA beneficiary to avoid all income tax liability otherwise due on the receipt of the account. To be eligible to disclaim, the beneficiary must not have benefitted in any manner from the IRA.

Further, the disclaimer must be in writing, irrevocable and unqualified, and delivered to the person possessing or having custody of the asset no later than the date which is 9 months after the date of the account owner’s death. If those conditions are met, the taxpayer avoids all tax liability due and payable with respect to the inherited IRA.

Note that there are other reasons besides taxes that a beneficiary may desire to disclaim an IRA inheritance. The beneficiary may not need the money and the IRA may be more useful to a co-beneficiary or a contingent beneficiary. Alternatively, the IRA beneficiary may have debt issues and desires to protect the account from his creditors by disclaiming it to another.

The disclaimer is a powerful tool available to IRA beneficiaries for post-death planning that shouldn’t be overlooked. A disclaimer lets the beneficiaries control where an IRA will go after the death of the owner to best meet the beneficiary’s own goals and objectives.

Are you having difficulties trying to manage distributions from an IRA or other retirement account? Give me a call, I can help.

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Inheriting an Inherited IRA – It’s complicated!

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In my last post, I outlined the key points to keep in mind when dealing with an inherited IRA. Unfortunately, the discussion may not end there. You may be the successor beneficiary of a previously inherited IRA.

In this situation, the IRA or other account was inherited by a prior beneficiary following the account owner’s death. Oftentimes the original account beneficiary will pass away before the IRA is completely liquidated. If that is the case, the successor beneficiary must know how the distribution rules will impact her.

The analysis begins by determining the date the original beneficiary inherited the IRA. (This is the date of the IRA account owner death.) Under current tax rules, if the IRA’s original beneficiary inherited the account on or before December 31, 2019, the distribution rules applicable to a successor beneficiary will differ from the rules that will apply if the original beneficiary inherited the IRA after December 31, 2019. Let’s look at each situation:

Did the original beneficiary inherit the IRA on or before December 31, 2019? If so, the successor beneficiary will have 10 calendar years following the year of the original beneficiary’s death to completely liquidate the IRA. This 10 year liquidation period will apply to any individual named a successor beneficiary. For instance, if the successor beneficiary is the original beneficiary’s spouse, he or she must liquidate the entire balance of the IRA with the 10 year term.

The successor beneficiary is not required to withdraw a minimum amount each year during the term. She may wait until the very end of the term to liquidate the IRA. The IRS will penalize her if she does not fully liquidate the account by the end of the 10 year term. The penalty will be equal to 50% of the balance remaining in the IRA at the end of the term. The IRS will levy the penalty each year until the IRA is liquidated.

Did the original beneficiary inherit the IRA after December 31, 2019? If the original IRA beneficiary inherited the account after December 31, 2019, the distribution rules applicable to the successor beneficiary will depend upon the status of the deceased original beneficiary at the time of his death. If the original beneficiary was an “eligible designated beneficiary,” or “EDB” (defined by the tax code), the successor beneficiary will have 10 years from the year of the original beneficiary’s death to liquidate the IRA.

An EDB may be: a) the surviving spouse or a minor child of the account owner: b) a disabled or chronically ill individual: or c) an individual not more than 10 years younger than the deceased account owner. The tax code deems all other individual beneficiaries to be “designated beneficiaries.” (A successor beneficiary will never be an EDB under the tax code.)

If the original IRA beneficiary was merely a designated beneficiary, then the successor beneficiary has only the remainder of the original beneficiary’s 10 year term to complete the IRA liquidation. She does not get a new 10 year term to liquidate the IRA.

Again, the required minimum distribution rules do not apply. However, the IRS will impose the 50% penalty if the account is not fully liquidated by the end of the original beneficiary’s 10 year term. A successor beneficiary will have to move quickly to liquidate the IRA if the original beneficiary died late in the last year of the 10 year term.

One must be on their tippy-toes in any situation involving an inherited IRA or other retirement account. She must be especially careful if inheriting a previously inherited IRA.

If you or someone you know is struggling to manage an inherited IRA or other retirement account, give me a call. I can help.

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A Few Pointers About That IRA You Just Inherited.

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According to Forbes Online, the largest private transfer of wealth will take place over the next 30 – 40 years as members of the Baby Boomer generation pass their wealth on to younger generations. Some estimates are that $30 trillion will change hands. A large portion of that wealth is held in tax deferred or tax free IRAs (traditional and Roth and other tax deferred retirement accounts. If you inherit an IRA, and aren’t the surviving spouse, there are major rule differences that you must heed.

First, the rules that govern distributions from an inherited IRA will differ depending upon the beneficiary’s classification. If the account owner died after December 31, 2019, only an “eligible designated beneficiary” may take distributions from an inherited IRA over her remaining life expectancy. Individuals who are “eligible designated beneficiaries” under the tax code are: a surviving spouse; a minor child; a disabled individual; a chronically ill individual; or an individual not more than 10 years younger than the deceased account owner. If you do not fall into one of those categories, you are deemed to be a “designated beneficiary,” and you must liquidate the entire balance of the inherited IRA (traditional or Roth) within 10 years of the year of the account owner’s death.

As a designated beneficiary, you are not required to take periodic distributions (such as an annually) from the account. The tax code merely requires that all of the money be withdrawn by December 31 of the 10th year following the year of the account owner’s death. You can wait until the very end of the liquidation window before withdrawing the balance of the account. But remember, if the account is a traditional IRA, distributions will be taxable income to you, so it may make sense to take periodic distributions to reduce the income tax bite. Distributions from an inherited Roth IRA are not income taxable.

Second, you cannot roll over an inherited IRA like you can your own account. While you inherited the account, you are not considered the account owner under the tax code. That is why the deceased owner’s name must be on the account title “for the benefit of” the beneficiary. If you do try to roll a traditional IRA over into an account in your own name, you have made an irreversible taxable distribution! So too with an inherited Roth IRA. While the distribution may not taxable, it cannot be reversed. All the potential future tax-free growth will be lost.

However, you may directly transfer an inherited IRA from one custodian to another. In this type of transfer, the account balance is sent directly from the old custodian to the new one. Caution! – You cannot directly transfer money from an inherited IRA to your own IRA in hopes of avoiding the rollover prohibition. The IRS will consider that to be an irreversible distribution as well.

Third, you cannot contribute to your inherited IRA. If you would like to put money away for your retirement, you will have to open your own IRA.

Fourth, if you are under age 59½, the 10% early withdrawal penalty will not apply to distributions from your inherited IRA. The rule does not apply to forced distributions from an inherited account.

Finally, you cannot convert your inherited traditional IRA to a Roth. Not only is this deemed to be an irreversible taxable distribution, but the funds cannot then be deposited into a tax-free Roth account. Any future earnings on the remaining balance will be subject to taxation.

If you are struggling to manage your inherited IRA, give me a call. I can help.

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COVID-19 Bill Eases Rules for Retirement Accounts.

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The COVID-19 stimulus (CARES Act) signed by President Trump last week includes some important tax relief for older retirement account owners.

First, The required minimum distribution (RMD) rules for Individual Retirement Accounts and 401(k)s are waived for 2020. If you haven’t taken your RMDs for 2020 yet, or have some RMDs left to take, you can leave the money in the account. The waiver applies to inherited retirement accounts as well.

This could be a bigger benefit than one might think. A 2020 RMD is based upon the account’s value as of December 31, 2019. If the value of a retirement account took a nose dive, the 2020 RMD (based upon a pre-correction value) would take a larger percentage of the account’s current value than otherwise would have been taken but for the correction. This waiver will give one’s retirement account a chance to recover without having the depletion caused by a forced RMD.

In addition, the IRS has extended the tax-filing deadline for 2019 federal income tax returns from April 15 to July 15. The extension postpones the deadline for making a prior-year contribution (for 2019) to a traditional and Roth IRAs to July 15. Be sure to indicate to the IRA custodian that the amounts contributed before July 15, 2020, are a 2019 prior-year contribution.

The CARES Act also waives the 10% pre-age 591/2 early distribution penalty on distribution of up $100,000 from IRAs and other retirement plans for individuals who meet the requirements of being affected by the coronavirus. Income taxes would still be due on pre-tax distributions, but could be spread evenly over three years, and the funds could be repaid anytime during the three years. Finally, rules for plan loans are relaxed for those who meet the definition of being affected by the coronavirus. Loan limits are increased and repayments postponed.

If you need assistance with your financial or retirement planning, give me a call, I can help.

Stay safe; wash your hands frequently!

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COVID-19 and Market History.

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We are several weeks into the COVID-19 (coronavirus) pandemic. The stock market has been is near free-fall as confusion, panic, and dare say hysteria grip the public. We don’t know how or when this crisis will reach the end of its course.

The graph below shows the performance of the S&P 500 from January 1980 to March 2020.  This period included the 1987 market crash, two gulf wars, the dot-com bubble, and the financial crisis of 2008-2009. The various down periods caused serious concern and even panic.  But notice that regardless of the cause of each downturn, and the market hysteria that ensued, the market always – always – recovered.

Successful investing requires patience and discipline.  Patience is the understanding that wealth is built over the long term and the ability to follow a long-term plan through short-term crises to achieving a long term goal.

Discipline is the ability to stick to your investment plan regardless of what the market, talking heads, or the investment herd is doing at any given moment.  While others are losing their heads, the important thing is to keep yours.  Even though the urge to “SELL!!!!” may be overwhelming, not reacting and maintaining a cool head will reward you in the long run.

It has been over 10 years since the last bear market (defined as a market-wide decline of stock prices of at least 20%) of 2008-2009.  We were actually long overdue for one.  While the cause of this crisis is different from previous ones, the eventual outcome will be the same.  The market decline will stop, the market will reorient and once again resume its inevitable upward climb to recovery and beyond.

The time-tested advice during volatile times is to not time the market (get out and get back in).   Doing so risks missing the strongest points of a recovery. By the time someone reacts to “stabilizing” evidence, she most likely missed the best opportunity for recovery.

We don’t know how far the market will drop, when the market will start to recover, or how long it will take to reach pre-crisis levels. But know one thing – it will.

The SECURE Act Sets a Tax Trap for IRA Beneficiary Trusts.

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The newly enacted Setting Every Community Up for Retirement Enhancement (“SECURE”) Act made major changes to the distribution rules for inherited IRAs. With few exceptions, the SECURE Act replaced the old life expectancy “stretch” IRA distribution rules with a mandatory 10 year distribution rule. This creates a potential tax trap for certain trusts named as an IRA beneficiary.

People frequently designate a trust as an IRA beneficiary. These trusts, often referred to as IRA beneficiary, or inheritance trusts, are designed to control and manage IRA distributions for beneficiaries. One popular type of IRA beneficiary trust is known as an “accumulation” trust.

An accumulation trust is frequently used in situations where the trust beneficiary may be unable to directly manage IRA distributions. An accumulation trust requires the trustee to retain IRA distributions in the trust. The trust does not pay out an IRA distribution to the beneficiary in the year received. The trust dictates the if and how IRA distributions will be paid to the trust beneficiary.

With few exceptions, the entire balance of an inherited IRA must now be distributed to the trust within 10 years of the account owner’s death. These distributions will be taxed at trust income tax rates because they are kept in the trust. An IRA distribution that exceeds $12,750 will be taxed at the highest marginal rate of 37%! Unless the IRA balance is very small, taxes will take a huge portion of IRA distributions, leaving a lot less for the trust beneficiary.

The SECURE Act’s 10 year distribution rule will impose significant tax burdens on many existing trusts and estate plans. More than ever you need to work with a qualified advisor who can help guide you through all the new rules and ensure you make the right decisions with respect to any changes to your retirement or estate planning.

Do you need help determining how best to best adapt your retirement or estate plan to the SECURE Act? Give me a call, I can help.

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Taking a Closer Look – The SECURE Act’s “Eligible Designated Beneficiary.”

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The Setting Every Community Up for Retirement Enhancement (“SECURE”) Act became law on January 1, 2020. The SECURE Act made major changes to the distribution rules governing inherited IRAs (both traditional and Roth) and company sponsored retirement plan accounts. In general, the Act requires a designated beneficiary of an inherited retirement account to withdraw the entire balance from the account within 10 years of the year of the original account owner’s death if the account owner dies after December 31, 2019.

However, the SECURE Act carved out a class of beneficiaries who remain eligible to take distributions from an inherited retirement account using the old life expectancy rules. Beginning January 1, 2020, an individual who qualifies as an “eligible designated beneficiary” may continue to use the life expectancy method to calculate minimum annual distributions from an inherited IRA or other retirement account. Those individuals eligible to use this technique are: (i) surviving spouses; (ii) children of the account owner who have not reached majority; (iii) disabled individuals; (iv) individuals who are chronically ill; and (v) beneficiaries not more than 10 years younger than the deceased account owner. All but the surviving spouse category bear a closer look.

Child of the account owner who has not reached majority. People may assume the term “majority” as used in the Act means age 18. For purposes of the new rules, a child could reach the age of majority at age 26. Under current Internal Revenue Code and Regulations, a child may be treated as not having reached the age of majority until age 26 if they have not completed a “specified course of education.” Thus, if both conditions are met, a surviving child of the deceased account owner may use the life expectancy method of calculating distributions until age 26. However, this may change with future regulations. Nevertheless, when the child reaches majority, he must then switch to the new 10 year distribution rule with regard to any funds remaining in the inherited account. This category excludes grandchildren of the deceased account owner.

Furthermore, a child who is disabled as defined in the Internal Revenue Code when he reaches majority may continue thereafter to use the life expectancy method of calculating minimum annual distributions so long as he continues to be disabled.

Disabled persons. Not all disabled persons may use the life expectancy method of calculating minimum annual distributions from an inherited retirement account. Under the Act, an individual is considered to be disabled if she is unable to engage in any substantial gainful activity by reason of a medically determinable physical or mental impairment which can be expected to result in death or to be of long continued and indefinite duration. (This is the same definition used to determine whether a pre-age 59½ withdrawal from an IRA will be subject to the 10% early withdrawal penalty.) The beneficiary must provide proof of her disability. If the beneficiary does not meet, or no longer meets this definition of “disabled,” she must use the 10 year distribution period mandated by the Act.

The chronically ill. Under the Act, a “chronically ill individual” is one who has been certified by a licensed health care practitioner as: (i) being unable to perform at least two activities of daily living for a period that is indefinite and reasonably expected to be lengthy in nature due to a loss of functional capacity , (ii) having a level of disability that is similar to the level of that described in clause (i) above, or (iii) requiring substantial supervision to protect the individual from threats to health and safety due to cognitive impairment. If the beneficiary is deemed to be chronically ill, he may use the life expectancy method to calculate minimum annual distributions from an inherited retirement account. This definition is stricter than the definition found in a typical long term care insurance policy, which will require that an individual be unable to perform activities of daily living for at least 90 days to be deemed “chronically ill.”

Individuals not more than 10 years younger than the deceased account owner. This category of eligible designated beneficiary includes surviving siblings, a domestic partner, or friends of the deceased account owner if they are not more than 10 years younger than the deceased. Any beneficiary falling within this category may use the life expectancy method of calculating required annual distributions from an inherited retirement account.

For any designated beneficiary who is not an eligible designated beneficiary under the Act, he or she must withdraw the entire balance of an inherited retirement account within 10 years after the year of the death of the account owner if the death occurs after December 31, 2019.

The SECURE Act brought significant changes to an already complex area tax law and will have an impact on many financial and estate plans. As with any tax law change, one should review their financial or estate plan to determine how these changes may affect them.

Do you need help understanding the impact the SECURE Act has on your current planning, or need help determining how best to adapt your financial or estate plan to the new law? Give me a call, I can help.

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