If you are experiencing financial distress during the COVID-19 crisis, you might be thinking about tapping into your Roth IRA to improve your cash situation. Yes, it is thoughtful, but before withdrawing from your nest, it is important to understand the constraints surrounding Roth IRA early withdrawal, including federal income tax consequences, especially if you are under 59½. This is even more important now that you could be eligible for a tax-free withdrawal.
Roth IRA withdrawal tax is a subject you should spend ample time on with an expert financial advisor for retirement. You may think that all withdrawals from Roth IRAs are federal-income-tax-free. Unfortunately, that is not true. Some withdrawals are taxable. On top of that, some early withdrawals (taken before you turn 59½) can potentially get hit with a 10% penalty tax.
Only qualified Roth IRA withdrawals are federal-income-tax-free. To be eligible for tax-free treatment, you must:
- Be at least 59½ (or dead or disabled)
- Have had at least one Roth IRA open for over five years.
The five-year period for determining if you pass the five-year test begins on January 1 of the first tax year for which you make a Roth contribution. It can be a regular annual contribution or a conversion contribution.
If both conditions are satisfied, all withdrawals from any Roth account set up in your name will be qualified withdrawals. As such, they are federal-income-tax-free and penalty-tax-free.
Complex Rules for Non-qualified Withdrawals
Any non-qualified Roth IRA early withdrawal is potentially subject to federal income tax. In addition, early non-qualified withdrawals are potentially subject to a 10% penalty tax on top of the income tax hit. You may also owe state income tax.
Non-qualified withdrawals most commonly occur in two scenarios:
- You take a withdrawal before age 59½
- You take a withdrawal before passing the five-year test.
If you own several Roth IRAs, you must aggregate them and treat them as a single account to determine which layer(s) each non-qualified withdrawal comes from and the resulting Roth IRA withdrawal tax consequences.
Exceptions for Certain Early Withdrawals
Any Roth IRA early withdrawal taken before you turn 59½ is, by definition, a non-qualified withdrawal, unless you are:
- Eligible for the special first-time homebuyer rule.
To be eligible for the first-time homebuyer rule, you must first pass the five-year test. In addition, you must spend the amount you have withdrawn within 120 days to pay qualified principal residence acquisition costs. There is, however, a $10,000 lifetime limit on this special rule. To the extent the special rule applies to your Roth withdrawal, the qualified amount is free from federal income tax and free from the 10% early withdrawal penalty tax.
The principal residence can be purchased by:
- The Roth account owner,
- The Roth account owner’s spouse, child, grandchild or grandparent, or
- A child, grandchild, or grandparent of the Roth account owner’s spouse.
The homebuyer (and the buyer’s spouse if the buyer is married) must not have owned a principal residence within the two-year period that ends on the acquisition date. Qualified acquisition costs are defined as those spent to acquire, construct, or reconstruct a principal residence, including closing costs.
Any Roth IRA early withdrawal that does not fall within one of the preceding exceptions is non-qualified and its pertinent Roth IRA withdrawal tax falls under the four-layer system.
Coronavirus-Related Roth IRA Distributions
Thanks to the Coronavirus Aid, Relief, and Economic Security (CARES) Act, you may qualify to take a tax-favored coronavirus-related distribution from a Roth IRA in 2020 only. To be eligible, you must be considered to have been adversely affected by the pandemic.
An eligible individual can take one or more coronavirus-related distributions from one or more Roth IRAs set up in their name, totaling up to $100,000. Subject to the $100,000 limit, such distributions are completely exempted from the 10% Roth IRA early withdrawal penalty tax.
Under complicated rules, you can recontribute a coronavirus-related distribution back into a Roth IRA within three years of when the distribution was received — and eventually avoid any federal income tax hit.
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Roth IRA early withdrawals might be what’s best for you, but it may not be the best long-term course of action. You may benefit from professional advice if your preparing to make that decision.
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