Ask The Experts: Money Matters

By Mike Miles

Converting traditional TSP to Roth 401(k)

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Q. I am an active-duty military officer with 17 years of service. I would like to convert my traditional Thrift Savings Plan account to a Roth 401(k) and pay taxes now. I want to see if it is possible to transfer my balance to a traditional 401(k) with my civilian investment company and then convert that account to the Roth 401(k). Additionally, I want to minimize my taxes by doing this during my deployment this year, because I will be receiving tax-free pay for most of this year. Is this allowed and/or possible? I would love to pay zero or low taxes on the deferred portion of my traditional TSP during this transfer.

A. This might be possible using an age based in-service withdrawal if you’re at least age 59½. Otherwise, it’s not.

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Adding 401(k) to TSP

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Q. I am a retired CSRS annuitant. What is the procedure to add external qualified 401(k) funds to the Thrift Savings Plan?

A. Use Form TSP-60, which includes thorough instructions.

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Military TSP vs. civil service TSP

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Q. I retired from active duty two years ago and have worked in civil service for one year.  I am contributing 10 percent of my civil service base pay and have a fairly good amount in my active-duty military Thrift Savings Plan. I am entertaining the idea of consolidating my TSP plans for a couple of reasons. First, simplicity of managing one account.  Secondly I believe, from what I have read on numerous sites, I will have greater control of current and future funds using the civil service side of TSP versus the active-duty military side. By this, I mean in-service withdrawals, loans, rolling over to another employer’s 401(k) plan (certainty of employment with civil service is at an all-time low), etc. Has my research misled me, or am I partially correct?

A. Convenience is an advantage. The basic rules for the accounts are the same, although you’re separated from military service and an active employee for the civilian account. This means that you may not take a loan from the military account but can take one from the civilian account. You could roll over the military account to an IRA or 401(k) now, but can’t roll over the civilian account. Whether the differences matter to you, or not, will depend upon your circumstances, but everything you need to know is available at www.tsp.gov.

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Is TSP considered ‘traditional IRA’ for tax purposes?

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Q. I own both a Thrift Savings Plan account and several non-TSP IRAs with other institutions and am approaching the age at which I must begin to withdraw the required minimum distribution from both the TSP and the non-TSP IRAs.

I am withdrawing enough money from the TSP to cover the required distribution from all of my accounts combined. Must I withdraw any additional monies from my non-TSP IRAs to comply with the tax laws? The answer may depend upon whether the TSP is considered a “traditional IRA” for tax purposes. I can’t find any information on this point.

A. The TSP is not considered an IRA for any purpose. From the Internal Revenue Service website:

“An IRA owner must calculate the RMD separately for each IRA that he or she owns, but can withdraw the total amount from one or more of the IRAs. Similarly, a 403(b) contract owner must calculate the RMD separately for each 403(b) contract that he or she owns, but can take the total amount from one or more of the 403(b) contracts.
However, RMDs required from other types of retirement plans, such as 401(k) and 457(b) plans have to be taken separately from each of those plan accounts.”

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72(t) distributions

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Q. I’m about to retire at age 47 after 25 years as a federal law enforcement officer. I plan to roll my 401(k) (TSP) over to a traditional IRA and begin taking substantially equal periodic payments per 72(t) from the IRA, which, as I understand, once I start, I have to continue until age 59 ½. I plan to use the annuitization method to make equal monthly withdrawals, but I would like to take the first year’s withdrawal in a lump sum to help pay off some debt. Will the IRS allow that without the 10 percent penalty, or do I have to consistently stick to either monthly or annual payments?

A. The IRS only cares about the annual requirement being met. They don’t care about how the money is distributed. Monthly payments are not required, and as long as you meet the annual 72(t) requirements, there should be no penalty.

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Transferring 401(k) post-tax funds from previous employer to Roth TSP

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Q. My previous employer allowed post-tax contributions to the 401(k) plan after the maximum allowed pretax contributions had been reached. Can I transfer the post-tax contributions of my previous employer’s 401(k) plan to the Roth TSP?

A. No.

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Are 401(k) and catch-up contributions earned income?

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Q. I plan to retire next year with 35 years of federal service (FERS) at age 56, and eligible to receive a Thrift Savings Plan supplement of about $18,000 per year.

Once I retire, I plan to work to earn approximately $38,000 per year. Of the earned income, I plan to contribute $17,500 to my 401(k) plan and an additional $5,500 toward the catch-up contribution. The remaining $15,000 will be reported as an earned income on my W-2 and Form 1040.

I plan to earn $38,000 for the year, so that my supplemental income will not be deducted $1 from my TSP supplemental benefit payments for every $2 I earned above the annual limit of 15,120.

Are the 401(k) and the catch-up contribution considered earned income that could reduce the $18,000 TSP supplement per year?

A. You’re talking about the FERS special retirement supplement, not a TSP supplement. Earnings you direct into a 401(k) plan are still considered earnings for the FERS Supplement Earnings Test.

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401(k)-to-CSRS rollover

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Q. I am the 401(k) specialist for our tribal government. We have a former employee who wants to roll over his 401(k) into making a deposit in CSRS. Is this possible? A transfer from CSRS into a 401(k) is not allowed, so should his attempted rollover be allowed?

A. This is not allowed. CSRS deposits are made with after-tax money.

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Repaying CSRS via rollover

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Q. I was first employed by the Defense Department in October 1982 and placed in CSRS. During a reduction in force, I lost my position in July 1994. In 1996, I withdrew my CSRS contributions and had them rolled into an annuity with American Express (now Ameriprise).

In November 1998, I was rehired by DoD and became a FERS employee. When I was rehired by DoD, I took the funds I had earned at my previous (1994-1998) job’s 401(k) and rolled them into the same annuity with Ameriprise.

I am now nearing retirement age and plan to buy back the CSRS time I lost by withdrawing my funds.

Can any of the annuity I have with Ameriprise be rolled into repaying my CSRS without any penalty or tax burden? I would think that, at the least, the amount that I withdrew in 1996 and rolled into the annuity could be rolled back into the CSRS. I am not trying to increase the amount of the CSRS, only to repay what I withdrew, plus interest due.

A. You made your original CSRS contributions with after-tax dollars and the money was not taxed when it was withdrawn. Your redeposit must again be made with after-tax dollars, so you can’t do what you’re asking about.

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RMD and still working at 70 1/2

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Q. I am 70 years old and still employed by the federal government. When I am 70½, I understand I must take a required minimum distribution from my traditional IRA/401s, but not clear if this applies to my Thrift Savings Plan account. Can you please tell me what the rules are for those who are 70 and over but still working for the government insofar as taking a required distribution from my TSP account? Can I wait until I retire from government?

A. You may wait until you retire. You may also be able to transfer your IRA/401k balances into the TSP to avoid or delay future RMD. Consult your tax preparer and www.tsp.gov for information and advice.

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