Maximizing Your Thrift Savings Plan Contributions In A Combat Zone


 

Quick review:  the military’s Blended Retirement System offers matching contributions to your Thrift Savings Plan, and in 2018 you can contribute up to $18,500.  In 2019 you can contribute up to $19,000.

 

[12 November 2018 update: This post has a minor (but important) revision after further confirmation with the TSP staff.  I’ve also added the 2019 contribution limits.]

 

Your contributions can go into your Roth TSP or into your traditional TSP (or in any combination of the two up to a total of $18,500 in 2018, $19,000 in 2019). As long as you contribute at least 5% of your base pay into your TSP every month of the year, then the Department of Defense will match up to 5% of your base pay all year long.

Better yet, that DoD match does not count against your elective deferral limit ($18,500 in 2018, $19K in 2019). Here’s the tax code reference from the TSP website with more details:

Image of the TSP table of contribution limits showing that the elective deferral limit of $18,500/year does not include the DoD BRS agency or matching contributions against that limit. | The-Military-Guide.com

 

Image of the TSP table of contribution limits showing that the elective deferral limit of $18,500/year does not include the DoD BRS agency or matching contributions against that limit. | The-Military-Guide.com

Of course if you’re in the military’s legacy High Three pension system then you’re also eligible to contribute that same $18,500 to your Roth or traditional TSP in 2018.  ($19,000 in 2019.)  You don’t get the DoD match but the IRS tax codes still applies.

 

[Note: in this post, we’re not going to rehash the debate about High-Three versus opting in to the BRS. See the related links at the bottom– especially if you’re eligible to opt in to the BRS.]

That’s it for the quick review.  Now we’re going to describe how to level up on TSP contributions.

 

Combat zone contributions

Because so many military families have learned the basics of contributing to the TSP, we’re getting a lot of questions about maximizing those contributions during deployments to combat zones. Military pay in a combat zone is exempt from federal and state taxes, and servicemembers are also eligible for much higher contributions to the TSP. I’ll get into the gory details during this post, but for now I’ll mention that the annual additions limit of the tax code is $55,000/year in 2018, and $56,000/year in 2019. That limit applies even when you’re not in the combat zone for the entire year!

Later in this post I’ll also answer the question that most of you are thinking right now:

Hey Nords, I just checked my Leave and Earnings Statement and, golly dude, I’m not getting paid $55K this *year*– let alone during this deployment. I have expenses, too. Where the heck are people getting the money for this?!?”

We’ll address that issue in excruciating detail (military families are extremely creative) but the basic response is “Do the best you can with what you have.” You’ll be surprised at how much the DoD and the IRS will help you reach that goal ($55K in 2018, $56K in 2019), and this post includes the links to make sure it applies to you.

Let’s be clear: I would not volunteer to deploy to a combat zone just for the tax-free pay (and the special pays) and the higher contribution limits to retirement accounts. I would not even do it to pay off student loans or consumer debt. Yet that combat zone is why you joined the military, and as long as you’re there then you might as well make the most of your pay advantages.

But that leads to a good question.

 

Why would anyone want to contribute $55,000/year (2018) or $56,000/year (2019) to their TSP?!?

Short answer: the TSP has some of the world’s largest passively-managed index funds with some of the world’s lowest expense ratios. Depending on how you contribute, you can get tax-deferred compounding and tax-free withdrawals. You don’t even have to wait until age 59.5 to tap your TSP.

The TSP is one of several investing answers, but it should be a big part of every military family’s asset allocation plan. (Some might decide it’s the best part.) In the combat zone, you’re putting tax-free pay into the TSP. This not only offers a huge compounding advantage but also means that you have more money to contribute to your TSP account instead of “contributing” it to the U.S. Treasury’s income-tax fund via withholding and tax returns.

Finally (stay with me here) combat deployments are not exactly fun. (Not even submarine deployments.) We personal-finance bloggers talk boldly about frugality versus deprivation and work-life balance, but let’s not kid ourselves: this deployment will be more work than life, and a lot more deprivation. As long as you’re embracing the suck, you can still extract some value from the pain by investing as much as you can toward your FI life goal.

For a few of us, maximizing TSP contributions *during* a deployment is a great way to minimize lifestyle expansion *after * a deployment. Yeah, you worked hard and you deserve a nice reward. Instead of a dollar-gobbling depreciating pile of pickup truck, how about sleeping better at night knowing that you’re on track for financial independence? Give yourself a small victory-lap party, sure, but avoid the temptation of the hedonic treadmill by putting most of that money where it’s hard to fritter away.

No worries, this post includes a detailed year-round example. I also have a spreadsheet for you to edit with your own numbers.

Next question: where are these combat zones?

Surprisingly, they don’t all involve actual combat. I hope.

 

Combat Zones

DoD and the Internal Revenue Service work with Congress to define combat zones. Here’s the text straight from the IRS press release:

The term ‘combat zone(s)’ is a general term used on IRS.gov and includes all of the following hostile areas where military may serve: actual combat areas, direct combat support areas, and contingency operations areas.”

I was surprised to learn that Djibouti, the Philippines, and even the Sinai Peninsula are eligible for combat zone benefits. (Yeah, they’re also awesome blogger keywords.) The distinction is not whether you’re shooting but rather whether you could be shooting or whether you’re helping other people shoot. You’re also supposed to be getting imminent danger pay or hostile fire pay.

According to the IRS, there are three options:

  • Service in an active combat area as designated by Executive Order, and receive special pay for duty subject to hostile fire or imminent danger as certified by DoD.
  • Service in a support area as designated by DoD in direct sustainment of military operations in the combat zone, and receive special pay for duty subject to hostile fire or imminent danger as certified by DoD.
  • Service in a contingency operation as designated by DoD, and receive special pay for duty subject to hostile fire or imminent danger as certified by DoD.

Read the fine print in the IRS notice, but if you’re getting that pay on deployment then you’re probably eligible for the tax code’s annual additions limit to your TSP:  $55,000/year in 2018, $56,000/year in 2019.

 

What’s the Annual Additions Limit?

What does that limit look like? Here’s another section of that table from the TSP contributions limits page for 2018 and 2019:

Image of table from the TSP website showing the annual additions limit of $55,000/year, which now does include the DoD BRS agency and matching contributions against the $55,000 limit. | The-Military-Guide.com

 

Image of table from the TSP website showing the annual additions limit of $56,000/year, which now does include the DoD BRS agency and matching contributions against the $56,000 limit. | The-Military-Guide.com

Here’s the important fine print from that chart:

This limit… includes employee contributions (tax-deferred, after-tax, and tax-exempt), Agency/Service Automatic (1%) Contributions, and Matching Contributions.”

In other words, that limit ($55,000 in 2018, $56,000 in 2019) now includes your DoD BRS agency/matching contributions. You’re not actually contributing all of that limit from your own pay.

 

How to reach the Annual Additions Limit ($55,000 in 2018, $56,000 in 2019)

1. Because that limit includes the BRS agency/matching contributions, you have to dial back your contributions to allow for DoD’s 5% match of your base pay. To make things even more complicated for the BRS, you’ll have to spread your 5% contributions across all 12 months of the calendar year or you’ll miss some of the match.

2. Here’s another good deal: by the definition of the combat zone, you’re getting more special pay (at least hostile fire or imminent danger pay). You lived without that money when you were in the U.S., and you can probably live without spending it in a combat zone. Since it’s tax-free, you can set your MyPay (or Marine OnLine) contribution percentage to 100% to contribute all of it to the TSP.

3. Some of you have planned ahead for the next good deal: bonus money. I am not a lawyer or a CPA or a CFP, and you’ll have to read your bonus contracts very carefully to make sure you’re eligible, but here’s the link: if you sign a bonus contract in a combat zone eligible for CZTE pay, then it’s not taxable.

Let’s be clear again: I would not volunteer to re-enlist or sign a bonus contract in a combat zone just for the tax-free pay. (Yes, I actually do get reader questions about how to volunteer for this.)  I would not even do it to pay off student loans or consumer debt. Yet if you’re planning to obligate the service anyway, or if you’re eligible to sign up for the BRS Continuation Pay bonus between 8-12 years of service, then as long as you’re in the combat zone you might as well make the most of your pay advantages.

Suddenly that annual additions limit might be within your reach.

4. Here’s another fine-print point which the BRS has highlighted: these annual addition limits are per calendar year, not just for the deployment. Let’s unpack that concept for several more paragraphs.

When you deploy to a combat zone (as defined above) then the IRS lets you use the annual additions limit for the entire calendar year– even for the days of the year when you weren’t in the combat zone. Your pay is only tax-free when you’re in the combat zone, but you still have the Internal Revenue Code’s annual additions limit all year long to continue contributing (taxable) pay.

[12 November 2018 update: I’m striking out that last paragraph after clarification from the TSP staff and adding this text:]

When you deploy to a combat zone (as defined above) then you’re eligible for the annual additions limit for the rest of the calendar year. You’re contributing tax-free pay when you’re in the combat zone, yet you can continue to contribute taxable pay to the TSP after you leave the combat zone.

But there’s a catch, and after I published this post it took me a couple more e-mails with the TSP to confirm it.

When you return home then any further contributions for the rest of the year are subject (again) to the elective deferral limits. You can not exceed $18,500 of contributions in the Roth TSP at any time during 2018. ($19K in 2019.) In addition, if your traditional TSP account has already exceeded $18,500 of contributions in 2018 ($19K in 2019) then you can’t contribute more taxable pay to it.

If you’re in the BRS, then you want to receive DoD’s matching contributions all year long. In order to do that, you need to leave room in your Roth TSP for all 12 of your monthly contributions. Read the section below titled “If You’re In The BRS…” to make your plan.

[See the bottom of this post for the verbatim details of the TSP staff’s interpretation of the tax law.]

 

If your deployment stretches from October 2018 to March 2019 (ouch, over the holidays) then you’re eligible for the annual addition limit of $55,000/year in 2018 and again for $56,000/year in 2019. Your pay was only untaxed while you were in the combat zone, but you get to use the annual additions limit twice in two calendar years.

Even if you just have a series of short deployments to combat zones during the years, the IRS is still going to let you use the annual additions limit all year long. You’re certainly paying the price for the benefit– use as much of it as you can.

Note that if you’re stationed in Qatar (another awesome blogger keyword) for two years, then you may be able to use the annual additions limit in three different calendar years. “See the world” with tax-exempt pay and higher TSP contribution limits.

5. Here’s another method that readers have shared with me: sell some investments from your taxable accounts. You’re going to want to seek professional tax advice from a CFP or a CPA, but this can save you quite a bit on capital-gains taxes.

Here’s the theory: your combat-zone income is tax-free so your taxable income for the year is very low. When you’re in a low income-tax bracket, your tax rate on long-term capital gains is… zero. For example, a married couple filing jointly pays no capital gains tax if their total taxable income is $77,220 or less.

This means you’ll raise your TSP contributions (in MyPay or Marine OnLine) as high as you can. Meanwhile you’d sell some of your investments in taxable accounts (within that 0% long-term capital gains limit) and use that money for living expenses. The net result? You’ve shifted a huge amount of money to the TSP and avoided a whole bunch of capital gains taxes.

6. One more idea, although it borders on irresponsible: if you’re a junior officer who’s taken out a career starter loan during college, then I’d be tempted to maximize my TSP contributions and live off the balance of that loan. You’d essentially be borrowing money at 1%-2% per year to invest in the TSP and then paying it back over a longer term. This is extraordinarily risky (high volatility, loss of principle, leveraged debt) but potentially profitable over a decade or longer.

Let’s cover one more piece of fine print about that annual additions limit, and then we’ll get to the example.

 

The Roth TSP annual contribution limit is still $18,500 in 2018 and $19,000 in 2019

(Even when you’re eligible for the higher annual additions limit)

Here’s that crucial fine print where the TSP computers can cut you off:

Image of the text in the fine print of the TSP contribution limits image explaining that the Roth TSP contribution limit is still $18,500 even if the annual additions limit of $55,000 is still in effect. | The-Military-Guide.com

 

Image of the text in the fine print of the TSP contribution limits image explaining that the Roth TSP contribution limit is still $19,000 even if the annual additions limit of $56,000 is still in effect. | The-Military-Guide.com

Here’s another way of saying it, from page #3 of this TSP fact sheet i:

Tax-exempt contributions made to the traditional balance of a uniformed services account while deployed to a designated combat zone do not count toward the tax code’s elective deferral limit. However, any Roth TSP contributions are subject to the Internal Revenue Code limit even if they are contributed from tax-exempt pay.”

When you’re contributing to your Roth TSP (and you should), then you have to stay below the Internal Revenue Code limit ($18,500 in 2018, $19,000 in 2019) until December’s contribution. This means that your overall annual additions limit is going to stay just under the elective deferral limit in the Roth TSP (with your last contribution of the year coming in December) and the rest of your contributions will go into the traditional TSP. Of course the DoD BRS agency/match contributions are always going into your traditional TSP (see paragraph 7.b.(12) of that link), so between you and DoD you’ll end up with the rest of your contributions in your traditional TSP account.

As soon as your Roth TSP contributions hit $18,500 in 2018 or $19,000 in 2019, no matter where you are or when it is during the year, the TSP computer system will cut you off. Any excess contributions from your pay will be used to reach the limit but the TSP will kick the rest of the excess back to DFAS. Even worse, the TSP will shut you down at the elective deferral limit ($18,500 in 2018, $19,000 in 2019) and lock you out of contributions for the rest of the calendar year.

 

If You’re In The BRS… then leave room in your Roth TSP for your monthly contributions

[This section is a 12 November 2018 update to the original post.]

We already know that you can only contribute to your Roth TSP up to the elective deferral limit. ($18,500 in 2018, $19K in 2019.) That limit applies at home and in the combat zone.

The TSP has confirmed that when you’re home from the combat zone, then you can only contribute to your traditional TSP up to the elective deferral limit. (See the edits above in paragraph #4, and see the TSP e-mail after the end of this post.) However while you were in the combat zone you did your best to reach the annual additions limit. ($55K in 2018, $56K in 2019.) That means that while you were in the combat zone you probably contributed way more than the elective deferral limit to your traditional TSP. If you did then now that you’re home, the TSP computers would have locked out further contributions to the traditional TSP.

If you’re locked out of TSP contributions before the end of the year, then you’re going to lose your DoD BRS matching contributions for the rest of the year. You earned a lot of tax-free pay during the deployment and you might have reached the annual additions limit in your TSP, yet you still lost out on free money.

However you can still contribute to your Roth TSP up to its elective deferral limit of $18.5K in 2018, $19K in 2019.

The solution: when you set up your plan for your year of TSP contributions, start with 5% of your base pay every month to the Roth TSP. That ensures you’ll have 12 months of Roth TSP contributions and 12 months of DoD BRS matching contributions.

Then fill in the rest of your plan using the spreadsheet template below. When you return home, you’ll probably be shut off from more contributions to your traditional TSP. (You’ve already blown through the elective deferral limit in your traditional TSP and you’re approaching the overall annual additions limit in you TSP.) However you still have room in your Roth TSP to reach its elective deferral limit before you reach the annual additions limit.

 

The Example: contributing $55,000 in 2018 to the TSP from a combat zone with the DoD BRS match

This example comes from a series of e-mails with the Federal Retirement Thrift Investment Board (the government agency which runs the TSP) and the DoD BRS office. I’ve shared those e-mails with other military financial bloggers and they may be writing their own posts on the subject.Image of the logo of the Federal Retirement Thrift Investment Board, the government agency which runs the federal and uniformed services Thrift Savings Plan | The-Military-Guide.com

This is one of the examples used at the FRTIB for the training of TSP employees, and they’re reportedly working on more comprehensive guidance for servicemembers. (I’m not sure when it’ll be released but I’ll update this post.) I’ve already asked the BRS office to connect us bloggers with the FRTIB so that we can continue the conversation and get specific links to the tax code.

The DoD BRS office also asked me to pass on:

Individual service member who are impacted by this should contact the TSP call center or a tax adviser for guidance on the impacts of IRS regulations on their contributions.”

Until we get Now that we have the IRC references and clarifications from the CPAs and the lawyers, please feel free to refer to this post with the DoD BRS office, DFAS, the TSP, and your pay/personnel office. This example is how the system is supposed to work. The BRS software implementation in the DFAS and TSP computer networks has hopefully fixed any glitches from 2017 or earlier.

At the end of this example I’ve included a screen capture of a spreadsheet and a link to the Google Sheet where you can tweak your own numbers.

Here’s a scenario for a servicemember who:

  1. Opted in to the Blended Retirement System.
  2. Contributes at least 5% to their TSP every month (for the full DoD matching contributions).
  3. Deploys to a combat zone to receive combat zone tax-exempt pay…
  4. … and their deployment is only part of the year (March – September 2018). They’re back home on 1 October 2018.

 

Here’s the FRTIB response, edited for easier blog-post reading:

================

I think are a lot of ways that a service member can do this and I’ll give an example.

Disclaimer: this is not advice and merely an example of one service member making contributions while in a combat zone.

Assumptions:

1. Service member who makes $48,000/year in basic pay and receives a $30,000 retention bonus while in a combat zone.

2. The elective deferral limit is $18,500 and the annual additions limit is $55,000.

Using these numbers, if the service member contributes 5% in January-February and 5% again in October-December, they will have contributed $200 per month of their own money and received agency/matching 5% of $200 per month.

If that happens, the service member will have contributed $1,000 towards the elective deferral limit (their own contributions) and $2,000 towards the annual additions limit (their own contributions and employer contributions).

That leaves the seven months in the combat zone to figure out how to contribute.

In this exact scenario, it likely makes sense to contribute to Roth up to the elective deferral limit less contributions made in January-February and October-December because those contributions will be tax-free going in and tax-free coming out so long as all of the other tax requirements are met.

In that case, there is $17,500 left towards the elective deferral limit ($18,500 minus the $1,000 contributed in the months while not in a combat zone). That divided over seven months is $2,500 per month of which there will be an additional agency/matching 5% contribution of $1,400.

This brings the total contribution to the TSP to $20,900 meaning the service member can contribute an additional $34,100 of tax-exempt money to their traditional account. That amount over a seven month period is $4,871 per month.

These amounts will allow for both the elective deferral and annual additions limit to be reached and the maximum amount of matching to be reached (5% of $48,000).

Of course, this service member could adjust the numbers to increase the contributions while not in a combat zone and decrease the amount while in a combat zone.

However, if the service member reaches the elective deferral limit before they leave the combat zone, they will not be permitted to make any contributions when they return.

=================

 

As you may have concluded by now, that has to be spreadsheeted to be clearly understood.

Image of a Google Sheet spreadsheet showing how to contribute up to $55,000/year of the annual additions limit to the TSP from a combat zone, while still receiving the full DoD BRS matching contributions and not exceeding $18,500/year in Roth TSP contributions. | The-Military-Guide.com

Here’s the link to that Google Sheet for maximizing BRS contributions to the Thrift Savings Plan from a combat zone.. Please note that to edit this spreadsheet you’ll have to copy it (“File | Download as…”) to your own device and then edit your copy.

 

What If You’re Still In The Legacy High Three Pension System?

The rules are still the same for your combat zone contributions, only you don’t have to worry about DoD’s BRS agency or matching contributions.

Remember to stay below the Roth TSP contribution limit, as I mentioned up in the BRS section. Here’s another way of saying it, from page #3 of this TSP fact sheet:

Tax-exempt contributions made to the traditional balance of a uniformed services account while deployed to a designated combat zone do not count toward the tax code’s elective deferral limit. However, any Roth TSP contributions are subject to the IRC limit even if they are contributed from tax-exempt pay.”

When you’re contributing to your Roth TSP (and you should), then you have to stay below the IRC limit. ($18,500 in 2018, $19,000 in 2019.) This means that your annual additions limit ($55K in 2018, $56K in 2019) is going to put just short of $18.5K ($19K in 2019) in the Roth TSP.  The remaining $36,500.01 of your contributions ($37,000.01 in 2019) will go into the traditional TSP.

 

[Reader update:
This comment just came in my Facebook messages:
“Hello, I read your article about maximizing TSP in a combat zone. I ran into an issue earlier in 2018. Before deploying in June, I had contributed about $18,300 to traditional TSP and $200 to Roth. When I arrived I was unable to make any more contributions to Roth, but I was able to contribute to Traditional. Why is this?”

My response:
If you contributed $18,500 to the TSP before deploying then you’d already hit the elective deferral limit ($18,500 in 2018) before arriving in the combat zone.  The TSP computers and DFAS would have locked you out of further contributions.

Now that you’re deployed, neither the TSP nor DFAS would have automatically restarted your contributions. Perhaps someone from your pay office (or DFAS) noted your combat-zone status and restarted the contributions. Since you had already reached your annual contribution limit (and they had to turn it back on) for some reason the TSP system wouldn’t accept new contributions to the Roth TSP.

I’m sorry this happened. Servicemembers who’ve opted in to the new Blended Retirement System are advised not to front-load their TSP contributions so that they can receive the monthly DoD BRS match all year long. This appears to be a similar issue with the TSP computer system.]

 

Note for “older” servicemembers

If you’re age 50 or older, then your 2018 limits include a $6000/year “catch up” contribution.

Image of the text for the catch-up contribution limits of the Thrift Savings Plan of $6000 | The-Military-Guide.com

You active-duty folks shouldn’t smirk at this clarification– you’d be surprised how many Reserve and National Guard servicemembers are in their 50s. That should tell you something about how challenging & fulfilling the Reserve & Guard can be if you’re feeling a little burned-out on active duty.

 

A Friendly Little Note From The IRS

Several servicemembers (and their frustrated spouses) have mentioned receiving IRS letters asking the servicemember to verify their deployment to a combat zone. One family was still receiving IRS letters about a 2016 deployment while the servicemember was deployed again in late 2017.

This letter is automatically generated by an IRS computer which tries to match the tax return to some sort of report that the servicemember has deployed to a combat zone. (Pro tip: this report to the IRS does not seem to come from DoD.) You’re welcome to call the IRS to confirm, but it’s not always easy to get a human to help you respond to the letter.  I’m not sure that an IRS human even sees the letter before it’s mailed to you.

Your best response to the letter 2761 request for your combat zone service dates is a written letter. If you want to be proactive then you can send the letter as soon as you return from deployment. (No operational security issues there!) You can also notify the IRS by e-mail about your combat zone service, but again I’d wait until you’re home for OPSEC.  Spencer over at MilitaryMoneyManual also has more suggestions about documentation and tracking the deployment dates.  As he suggests, save copies of your Leave and Earnings Statements which cover the duration of the deployment.

The whole point of volunteering this information to the IRS is to give them your information to create an entry in your taxpayer account database telling the agency that you deployed to a combat zone. That way when your tax return arrives at the IRS months later, the computer will already have a flag in the system to confirm your service. Ideally it won’t spit out a form letter.

 

One more special note: an extended deadline to contribute to your IRA

During my research for this post, I learned that you may even be able to contribute to last year’s IRA. Seek professional advice from a CFP or a CPA before you do this.

 

Your Call To Action:

Once again, if you’ve opted in to the BRS then make sure you’re contributing at least 5% of your base pay to the Thrift Savings Plan for the BRS match. Even if you’re still paying off debt, it makes sense to contribute to your TSP to at least get DoD’s free money in your TSP.

When you know your deployment dates, download that spreadsheet and make your TSP contribution plan. It’d be great if you had the income or assets to reach the annual additions limit ($55,000 per year in 2018, $56,000 in 2019), but do the best you can.

Whatever you decide to contribute, make sure you stay below an annual contribution of $18,500 in 2018 or $19,000 in 2019 in the Roth TSP or you’ll be locked out of additional contributions for that calendar year. When you’re in the BRS, that limit lockout will keep you from earning DoD BRS matching contributions for all 12 months of the year.

 

 

[The rest of the story:
In my opinion, the FRTIB’s policy is not clear in the tax code or in the TSP’s pamphlets and website.

I formed this opinion when an AFC and at least three other CFPs have been unable to find a clear reference to the FRTIB’s policy in the tax code or in the TSP’s public materials. (Despite one of them having seen the TSP’s training materials about the limits.) However two servicemembers have already been locked out of further TSP contributions in 2018. We knew they’d followed the rules on their Roth TSP limits. That meant there still could have been a glitch in the TSP computer system’s BRS software, or that there’d been another mistake with implementing the legislation. Or… the TSP’s guidance on the annual additions limit was ambiguous.

The FRTIB says that it’s not a computer glitch. DoD’s BRS office (and Congress) can decide whether this is the way they want the TSP to work. There’s already been at least one proposal to change the tax code for Reserve/Guard servicemembers in the BRS who have highly-paid civilian jobs with 401(k) plans. My confusion over the annual additions limit would appear to be yet another unintended consequence of the BRS legislation on TSP contributions.

The good news is that the TSP training team has taken aboard our feedback and is updating their Blended Retirement System training materials. I’ll stay in touch with the TSP and with the DoD BRS office.

Here’s the FRTIB’s verbatim interpretation from one of their TSP Training & Liaison Specialists– one of the people handling the TSP’s Education and Outreach program.
“The answer is “no,” this individual already met their 402(g) elective deferral limit, and therefore would no longer be allowed to make contributions to their TSP (contributions that apply to the 415(c) limit and NOT the 402(g) limit are only CZTE pay contributions, so therefore if you are no longer receiving CZTE pay, any contributions apply to the 402(g) limit, which again, was already met).”

Let me break down that 65-word sentence into smaller clauses.

When you return home from the combat zone, you can still contribute to your TSP accounts– but only up to the elective deferral limit ($18,500 in 2018, $19K in 2019) in each account. The TSP’s website and pamphlets are clear on only being able to contribute combat zone tax-exempt pay above the elective deferral limit in the traditional TSP when you’re in the combat zone. However they’re not so clear on how you can contribute taxable pay to your traditional TSP after you return home.

One of my smarter friends (a military retiree and a CFP) suggested thinking of it this way: when you’re home, count down from the limits instead of counting up. “How much have I reduced my elective deferral limit in each of my TSP accounts? How much room do I have left to contribute to each one?”

Alert readers will note that the servicemember in the contribution spreadsheet example received a $30K retention bonus while in the combat zone. If they signed that contract in the combat zone, then every one of the subsequent annual installments of that bonus is also tax-free… even if they’re not in the combat zone. Could they contribute the next few years’ installments of that CZTE pay to their traditional TSP up to the annual additions limit?

My answer: I don’t know. I’m going to let the FRTIB and the BRS office clarify those interpretations of the tax code. The good news is that DFAS already knows the bonus contract is tax-free and will reflect it on your W-2.]

 

 

 

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Related articles:
Where To Learn About The Military’s New Blended Retirement System (All the official sites and videos plus 32 posts by eight different bloggers– everything we’ve written over the last couple years.)
Thrift Savings Plan Contributions In A Combat Zone With The Blended Retirement System
Contribution Limits of the Thrift Savings Plan + 401(k) + IRA = ?!?
How To Maximize The BRS If You Decide To Opt In
Early Withdrawals From Your TSP and IRA After The Military



WHAT I DO: I help you reach financial independence. For free. I retired in 2002 after 20 years in the Navy's submarine force. I wrote "The Military Guide to Financial Independence and Retirement" to share the stories of over 50 other financially independent servicemembers, veterans, and families. All of my writing revenue is donated to military-friendly charities.

17 Comments
  1. Doug, I spent 5 months in a ctez but left the tax free zone toward the end of July and returned home in August. I planned on contributing more than the 18500 this year but as soon as I reached the 18500 limit, tsp stopped deducting from my paycheck. I was mostly contributing to roth and specifically changed to traditional once I was near the 18500 limit. Even with changing my contributions to traditional my tsp deductions stopped when I reached the 18500 limit. When I called the tsp help desk number, they told me the additions limit only applied while I was still in the tax free zone. I dont think that is correct. What can I do?

    • Doug, I think I need to clarify my post. I am not eligible for brs and therefore not contributing to brs or getting matching contributions. My problem is TSP is not letting me contribute more than 18500 total even though I was in a tax free zone during this calendar year. I have emailed them and contacted them by phone but they are of no help. Do you have a contact that would help me? Or can you help me? If it would help, do you have an email I can contact you with
      directly?

      • I think you’re doing everything right, Jeremy, but you’re always welcome to e-mail me at NordsNords@Gmail.com.

        It’s possible that the TSP computers have ignored the combat zone deployment because you didn’t exceed the $18,500 elective deferral limit during the deployment. One way to test that would be to try to contribute to your Roth TSP (and get up to $18,500 in just the Roth TSP). That seems to be possible from the contribution example obtained from the FRTIB and the spreadsheet that I built from it, although that spreadsheet example exceeds the traditional TSP’s EDL during the deployment.

        Another option would be to have your finance office request that the TSP restore your ability to contribute to the Roth TSP. I’m not sure whether that’d take effect in time for more than the December TSP contribution. That contribution would be deducted from your pay at the end of December and sent to your TSP account during the first week of January.

        My contact at the TSP has been reading this post (and a Facebook group discussion of the same topic). She’s committed to improving the public availability of the training materials about the contribution limits. I’ve also sent an update of the entire discussion to the DoD BRS office. They’re focused on the BRS program, but the TSP policy affects both BRS and High Three contributors.

    • Jeremy, I’m on your side in this analysis. Your comment is the latest of a series of reader questions which I’ve pursued with the TSP.

      I’ve quoted the TSP’s response above and edited the post to clarify what limits apply to which situations. They interpret the tax code to mean that contributions from taxable pay are bound by the elective deferral limit ($18,500) when you’re back home from the deployment– in the traditional TSP account as well as the Roth TSP account.

      This would mean that the only way to ensure all 12 months of DoD’s BRS match would be to leave room in the Roth TSP. (That’s part of the spreadsheet provided by the TSP.) During the deployment, the priority for combat zone tax-exempt pay would be contributing to the traditional TSP (even though the Roth TSP is easier to handle after leaving the military). After returning home the priority would revert back to the Roth TSP since the DoD BRS match could continue to be added to the traditional TSP (up to the annual additions limit).

      In your situation, it appears that the best you could do would be to leave the traditional TSP at $18,500 and finish up the Roth TSP to $18,500. The rest of the post has a section about spreadsheeting contributions for 2019 to leave enough room in the Roth TSP for all 12 months of DoD’s BRS match.

  2. Doug-
    I have had continuous issues attempting to get my Mypay account to allow any contributions to Traditional TSP while deployed. For 2 months I have attempted to put 92% of basic pay into the traditional TSP, appears that it has been accepted (screenshot saved), yet I have maxed out at $18500. I have spent several hours on the phone with milpay representatives and there has been no resolution. What can I do to get my contributions corrected? The online messaging obviously goes to a clerk that is able to do little other than offer a cut and paste response, and the phone operators are helpful to some degree, but always ends with a “looks good for next month” closure, but I have not been able to contribute more to my account. I would like to have email exchanges that I can document and file a complaint with the IG if needed, but I can’t seem to find any POC to attempt to get recourse.

  3. Reply
    dan@keepinvestingsimplestupid.com November 3, 2018 at 7:14 AM

    Hey Doug,

    Great post! I have a question/clarification regarding the DoD’s match. I just deployed and I am in the BRS and my question is regarding what happens to the BRS match once you go over $18,500 for a year.

    Does the 5% match go away? I’m mostly looking at 2019 – I want to max out my Roth TSP ($19,000 now!) asap in 2019 and then contribute to the Traditional TSP as much as I can up to the $55,000 limit – BUT – will my DoD 5% match stop for the year? I would hate to miss out on the majority of the 5% matches for 2019, but I also want to save as much as possible!

    Any idea how that works for sure?

    • Dan, you’ve asked a very pertinent BRS question, and I just received the TSP’s response.

      If you’re still in the combat zone at the end of 2018, then you can contribute to the Roth TSP just short of $18,500 (as specified on the TSP’s 2018 contribution limits page) and to the traditional TSP for the rest of 2018’s $55K annual additions limit. (That would be another $36,500.) Note that you’ll have to leave room in the traditional TSP for the DoD’s BRS agency/matching contributions, so your personal contributions will be short of that $55K total. Put your own numbers in the spreadsheet which is linked to this post.

      In 2019 you’ll still have to keep your Roth TSP below the 2019 limit of $19K. You can stuff as much as you’re allowed into your traditional TSP– up to the 2019 AAL of $56K, which still includes DoD BRS agency/matching contributions. As soon as you return home, however, the TSP interprets the 401(k) law to mean that your traditional TSP account limit also reverts to the elective deferral limit ($19K for 2019). That means anything above $19K in your traditional TSP when you come home would lock you out of the traditional TSP for the rest of 2019.

      The 2019 solution is to leave room in your Roth TSP for 5% base pay contributions for all 12 months of 2019. Then contribute to the traditional TSP until you’re home. If you’ve contributed >$19K to the traditional TSP by the time you return home, then you’ll be locked out of more contributions to your traditional TSP.

      However you’ll still have room in your Roth TSP for the rest of the year’s 5% base-pay contributions, which will enable the DoD BRS matching contributions to be added to your traditional TSP.

      In short, follow the example spreadsheet (with your own numbers) which is linked to this post– note that all 12 months of the BRS 5% base-pay contributions are all in the Roth TSP.

  4. Great post! Could you clarify the statement “That limit applies even when you’re not in the combat zone for the entire year!” A uniformed service TSP participant is still limited to the elective deferral limit when not in a CZTE, which includes their traditional contributions from taxable pay and always Roth contributions. My understanding of the regulations match what Marcus was told by the TSP representative. The only contributions that can exceed the EDL while not in a CZTE area are agency automatic/matching contributions.

  5. Thanks for the info and article! Do you have a spreadsheet that includes formulas? I’d like to edit my own assumptions, etc and don’t want to tweak each box…

  6. Also one other comment: If you receive a bonus while deployed then the entire bonus will be tax free if you are enlisted but as an officer most of the bonus will likely be taxed since officer tax-free pay is limited to the highest enlisted pay per month during that year.

  7. “the IRS lets you use the annual additions limit for the entire calendar year– even for the days of the year when you weren’t in the combat zone”. This is basically my situation right now. However, I was under the impression that my annual addition limit could only be filled while I was actually deployed. So for 2019, if I return from my deployment in January the only money over 18,500 that I could contribute to my TSP would have to be deposited to my traditional account during the actual month of January. When I get back, my limit would be $18,500 minus however much I already have in my Roth TSP. I believe I called TSP about this before I left, however I could have received bad advice from the rep I received. Do you have a reference stating I will be allowed to go over the $18,500 limit even when I return from my deployment next year?

    • Great question, Marcus, and it’s a confusing topic.

      I sent this post’s deployment timeline to the DoD’s Blended Retirement System office, and they coordinated the response with the TSP staff. Note that the quotes and the spreadsheet numbers come directly from the TSP, and they said that info is used as training material for their employees. Feel free to quote the TSP’s response in this post to the TSP reps.

      First you’d want to check that your unit indeed meets the DoD and IRS requirements for a combat zone in 2019 and is not simply in transit from the zone. (This is especially important for Navy deployments.) Then you can test the TSP’s software by treating your 2019 contributions as eligible for the annual additions limit. Of course your tax-exempt pay ends as soon as you leave the combat zone but you’ll still have your remaining base pay, special pay, and any other bonus pay for your TSP contributions.

      The best way to test this in 2019 would be to contribute more than $18,500 to the traditional TSP. When that works then you could decide where you want to put your remaining 2019 AAL contributions, but you’d have to stay short of the $18,500 limit in your Roth TSP. Keep in mind that the DoD BRS agency & matching contributions are also part of the AAL’s $55K total, so you’ll want to edit the post’s spreadsheet for your 2019 plan to make sure it all works out.

      Of course if the TSP shuts off your traditional TSP contributions when you reach $18,500 then please let me know. I’ll query the DoD BRS office and the TSP’s legal staff.

  8. This is a great overview and a huge advantage for deployed service members to take advantage of. I just gave a briefing to a group of soldiers about this very topic and there was a lot of interest in it. I hope we can continue to get more of the word out so that even if it is not possible to contribute 55,000 you can contribute a decent portion of your tax-exempt pay and make an investment in your future self!

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