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how exactly did that work?

15% on withdrawals over 160K? 15% on accounts over 160K
( to me, the latter sounds onerous.. the former would rarely apply )

It was above a $160,000 annual withdrawal based on substantially equal periodic payments over your lifetime. Effectively, the portion of an RMD above $160,000 would have a 15% penalty.

AS you said, only a handful of people would fall into this category.

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