Luisa Deal - Page 3




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          manner provided under section 72.  Section 408(d)(3) provides an            
          exception to the general rule for certain "rollovers" by the                
          distributee; namely, where a distribution is paid to the                    
          distributee, and the distributee transfers the entire amount of             
          the distribution to an IRA or an individual retirement annuity              
          within 60 days of receipt.                                                  
               Section 72(t)(1) provides for a 10-percent additional tax on           
          distributions from qualified retirement plans.  Section 72(t)(2)            
          excludes qualified retirement plan distributions from the 10-               
          percent additional tax if the distributions are:  (1) Made on or            
          after the date on which the employee attains the age of 59-1/2;             
          (2) made to a beneficiary (or to the estate of the employee) on             
          or after the death of the employee; (3) attributable to the                 
          employee's being disabled within the meaning of section 72(m)(7);           
          (4) part of a series of substantially equal periodic payments               
          (not less frequently than annually) made for the life (or life              
          expectancy) of the employee or joint lives (or joint life                   
          expectancies) of such employee and his designated beneficiary;              
          (5) made to an employee after separation from service after                 
          attainment of age 55;2 or (6) dividends paid with respect to                
          stock of a corporation which are described in section 404(k).  A            



               2                                                                      
                    This provision, codified at sec. 72(t)(2)(A)(v), is not           
          applicable to premature IRA distributions.  See sec. 72(t)(3)(A).           




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