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Medicare IRMAA Appeal (a.k.a. Request for Reconsideration)

In general, once you become eligible for Medicare (either by reaching age 65 or by being on Social Security disability for two years), your Medicare premiums for a given year are based on your modified adjusted gross income (MAGI*) from two years prior. For example, a person’s 2022 premiums are based on their 2020 income level.

The law is written this way for a simple pragmatic reason: “two years ago” is generally the most recent data Medicare has at the time they must determine your premium for a given year. For example, a person’s 2022 Medicare premiums must be determined in 2021 — at which point Medicare doesn’t have the person’s 2021 information yet, so they use 2020.

However, the law also provides that, if your income declines significantly from one year to the next due to a “life changing event” you may request that your premiums be based on that more recent year’s level of income, rather than your income from two years ago. This request may be referred to as a “request for reconsideration”, “Medicare Part B premium appeal”, or “Medicare IRMAA appeal.” Life changing events include:

  • Marriage,
  • Divorce/annulment,
  • Death of a spouse,
  • You or your spouse stopped working or reduced the hours that you work,
  • You or your spouse experienced a loss of income-producing property that was not at your direction (i.e., you did not intentionally sell the property), or
  • You or your spouse experienced a cessation, termination, or reorganization of an employer’s pension plan.

Filing Form SSA-44 is how you make such a request for reconsideration.

Why Is This Important?

In short, this is most likely to be important for:

  • High earners who retire in a year they (or their spouse) turn 63 or older or
  • High earners who retire when their spouse is receiving Social Security disability benefits.

Consider this example: Amanda and Neil collectively earn about $250,000 per year. They both retire in June of 2022, at age 64, after having earned roughly $120,000 for the year. When they begin Medicare at age 65 in 2023, their premiums will initially be based on their 2021 level of income ($250,000), which puts them in the third Medicare IRMAA tier.

They can, however, file an IRMAA appeal and request that their premiums instead be based on their 2022 income level. The net result is that they save $180.30, per month, per person in Medicare Part B and D premiums by filing Form SSA-44.

*For Medicare IRMAA purposes, MAGI is calculated as your adjusted gross income, plus tax-exempt interest, plus any foreign earned income or income from US territories that was excluded from your gross income.

Retiring Soon? Pick Up a Copy of My Book:

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Can I Retire? Managing a Retirement Portfolio Explained in 100 Pages or Less

Topics Covered in the Book:
  • How to calculate how much you’ll need saved before you can retire,
  • How to minimize the risk of outliving your money,
  • How to choose which accounts (Roth vs. traditional IRA vs. taxable) to withdraw from each year,
  • Click here to see the full list.

A Testimonial from a Reader on Amazon:

"Hands down the best overview of what it takes to truly retire that I've ever read. In jargon free English, this gem of a book nails the key issues."

Roth Conversion Analysis: Not Breakeven Analysis

A reader writes in, asking:

“I am planning to do a smallish conversion each year before I turn 72. I am 66.

Now though, I recall hearing a CFP say that it is important also to do a ‘breakeven analysis’ before converting money from a traditional to a Roth IRA. He has found that, for most of his clients, the breakeven point is too distant for a conversion to provide a meaningful benefit. Clients would have to be in their 90s.

If you have room in your blog, please touch on what a “breakeven analysis” is in the context of a Roth conversion and how to do it.”

This is a common misconception — one that is common even among financial professionals, unfortunately.

In most cases, breakeven analysis simply is not applicable to a Roth conversion decision. (There is one specific exception, discussed below.) For a Roth conversion decision, the length of time in question usually does not matter at all.

The reason has to do with the commutative property of multiplication. That’s the rule from grade school math that tells us that A x B x C is the same as C x B x A. The order in which we multiply figures is irrelevant — we get the same answer every time.

When you pay taxes on a distribution from a tax-deferred account, it’s a multiplication function. For example, if you take a distribution and you have a 20% total marginal tax rate, you’d be multiplying the amount by 0.8 in order to see how much is left after taxes. And the same is true for a Roth conversion, if you pay the tax from the IRA.

Imagine that you are considering doing a $50,000 conversion. And imagine that you have a 20% tax rate right now. If you convert it, you’re left with $40,000 in a Roth IRA. And the Roth IRA can now grow tax-free, which means your after-tax value can be represented as:

  • $50,000 x 0.8 x Year-1 return x Year-2 return x [any additional years of returns]

(Note that in the above, a 7% return would mean multiplying by 1.07. A negative 5% return would mean multiplying by 0.95.)

Or, you can keep the money in a traditional IRA, let it grow, and pay tax later. If we assume that you would also have a 20% tax rate later, then your after-tax value can be represented as:

  • $50,000 x Year-1 return x Year-2 return x [any additional years of returns] x 0.8

And the key point here is that those are the same thing. It doesn’t matter whether the returns are good or bad. Nor does it matter how many years of returns there are in between. It’s a textbook case of the commutative property of multiplication.

Breakeven analysis is predicated on the concept that you’re paying some cost up front, which is bad, and that you have to wait for some period of time before paying that cost is “worth it.” But with Roth conversion analysis, if you don’t pay the cost now, you have to pay it later (i.e., the cost cannot be completely avoided). And because the figures in question are all multiplication, it’s no worse to pay it sooner rather than later. (And in fact paying it sooner is often advantageous, because waiting until later to pay the tax often means the distributions themselves are larger — because the account has grown — which can itself increase the rate of tax. And again, the rate of tax is what we care about.)

Some smarty-pants might say, “but you’re forgetting time value of money! Time value of money tells us that it’s better to pay the cost later.” Nope. Not in this case. If the cost were a fixed dollar amount, that would be true. (Because then what we’re doing is subtraction. And once you mix subtraction in with a bunch of multiplication, the order becomes important.) Paying $10,000 today is worse than paying $10,000 several years from now.

But the tax on a distribution from a retirement account is not a fixed dollar amount. It’s a percentage. Paying 20% now vs. 20% later really does not matter. (Again, see our two bullet point options above. They’re the same.)

The Roth conversion question is generally just about whether you can pay a lower percentage now than you would pay later. If so, a Roth conversion is advantageous. And that would be true even if you planned to take the money out of the account next year (assuming, that is, that you’re at least age 59.5, so we don’t have to worry about the Roth conversion 5-year rule).

Again, we can just try the math for ourselves to demonstrate. Imagine it’s again a $50,000 amount you’re considering converting. And imagine that you have a 15% marginal tax rate this year, and a 25% tax rate next year.

If you do a Roth conversion, the after-tax amount is: $50,000 x 0.85 x the return over the next year.

And if you don’t do a Roth conversion (and instead take the money out of the account next year) the after-tax amount is: $50,000 x return over the next year x 0.75.

No matter what you plug in for the return, the first option is better. No need for the money to be in the account for a given length of time. (Again this is assuming that you’re at least age 59.5. Otherwise we have the Roth conversion 5-year rule to consider.)

When Breakeven Analysis Does Apply to Roth Conversions

As noted above, if the tax rate you would pay on a conversion is lower than the tax rate you would pay when the money comes out of the account later, a Roth conversion is advantageous. But there’s one case in which it can make sense to do a Roth conversion even when your current marginal tax rate is slightly higher than the marginal tax rate you expect to face later. Specifically, that can occur if you aren’t paying the tax out of the IRA but rather paying the tax out of assets you have in a taxable account.

And that’s when a breakeven analysis could apply. Because in that case, we’re no longer multiplying the IRA assets by a given figure, to represent the tax paid on the conversion. Instead, the entire amount taken out of the traditional IRA is going into the Roth IRA. And you’re paying the tax from somewhere else. (Effectively, you’re using taxable assets to “buy more” Roth IRA space.) And whether it makes sense to do that depends on a whole bunch of things, one of which is the length of time that the money will stay in the Roth (i.e., how long do you get to benefit from the tax-free growth that the assets will now experience, because they’re no longer in a taxable account). Other factors that are relevant in such a situation include:

  • What rate of return you anticipate earning on the assets,
  • What rate of tax you would have to pay on that return (and when you would have to pay it), if the assets stayed in a taxable account,
  • What (if any) tax cost is incurred as a result of selling the taxable assets in question now in order to use that money to pay the tax on the conversion.

But if I’m being honest, I would be reluctant to recommend a conversion to anybody if they’re paying a higher rate of tax on the conversion than they expect to face in the future, even if a breakeven sort of analysis showed that it might ultimately be advantageous. In most cases, I think it’s best to simply compare the tax rates, and if the current marginal tax rate is lower than the anticipated future marginal tax rate, a conversion is advantageous. And if you’re paying the tax out of taxable assets, then, great, it’s a little bit more advantageous.

Retiring Soon? Pick Up a Copy of My Book:

Can I Retire Cover

Can I Retire? Managing a Retirement Portfolio Explained in 100 Pages or Less

Topics Covered in the Book:
  • How to calculate how much you’ll need saved before you can retire,
  • How to minimize the risk of outliving your money,
  • How to choose which accounts (Roth vs. traditional IRA vs. taxable) to withdraw from each year,
  • Click here to see the full list.

A Testimonial from a Reader on Amazon:

"Hands down the best overview of what it takes to truly retire that I've ever read. In jargon free English, this gem of a book nails the key issues."

Which Dollars to Spend First Every Year in Retirement

There’s a common refrain in retirement planning that you want to spend from tax-deferred accounts when your marginal tax rate is low (as is often the case in years after you retire but before Social Security and RMDs kick in). It’s true that it’s better to spend from tax-deferred accounts than from Roth accounts when your tax rate is low. But there are other dollars that you want to spend first every year.

Let’s consider an example. Imagine that, in a given month, you’re trying to decide from which account to draw your next $1,000 of spending. And let’s also imagine that, so far this year, your taxable income has not yet fully offset your standard deduction and credits for the year. In other words, you currently have a marginal tax rate of 0%.

The obvious approach — let’s call it Option A — is to take the $1,000 out of your traditional IRA. Option A sounds pretty good, because this would be a tax-deferred distribution that’s completely tax-free. That sounds like as a good a time as any to spend from a traditional IRA, right?

Probably not. Because there’s likely an Option B: spend $1,000 from your regular taxable checking account, and do a $1,000 Roth conversion.

In each case:

  • You have spent $1,000,
  • You have removed $1,000 from your traditional IRA, and
  • You have incurred no tax bill.

But with Option A the remaining $1,000 is in your taxable checking account, whereas with Option B the remaining $1,000 is now in a Roth IRA. In almost every case, you’d rather have $1,000 in a Roth IRA than in a taxable account, because further earnings in the Roth will generally be tax-free.

The point here is that, if you have taxable-account assets that you can spend without generating any tax cost, it makes sense to spend those assets before spending retirement account assets. And if, when following such a plan, you have low-tax-rate space in a given year that you wouldn’t otherwise be using up, you can fill that space with Roth conversions.

In other words, every year before spending any dollars from retirement accounts (other than RMDs), you first want to spend from:

  • Earned income (i.e., wages, self-employment income),
  • Social Security income,
  • Pension/annuity income,
  • Interest and dividends from holdings in taxable accounts (note that this includes taxable and tax-exempt interest, as well as qualified and nonqualified dividends),
  • RMDs from tax-deferred accounts, and
  • Assets in taxable accounts that have basis at least equal to the current market value.

Again, the key thing that everything on that list has in common is that there’s no further tax-cost associated with spending these dollars. You have likely had to pay taxes on these dollars, but you don’t have to pay any more tax a result of spending these dollars.

Also, to be clear, this is not a discussion of how much to spend each year. For some people, it does not make sense to spend all of those dollars every year (so some dollars will get reinvested). And for other people, the intended total level of spending exceeds the categories above, so it then becomes a question of whether to spend from tax-deferred accounts, spend from Roth accounts, or liquidate taxable assets for which there would be a tax cost.

Retiring Soon? Pick Up a Copy of My Book:

Can I Retire Cover

Can I Retire? Managing a Retirement Portfolio Explained in 100 Pages or Less

Topics Covered in the Book:
  • How to calculate how much you’ll need saved before you can retire,
  • How to minimize the risk of outliving your money,
  • How to choose which accounts (Roth vs. traditional IRA vs. taxable) to withdraw from each year,
  • Click here to see the full list.

A Testimonial from a Reader on Amazon:

"Hands down the best overview of what it takes to truly retire that I've ever read. In jargon free English, this gem of a book nails the key issues."

Roth Conversion Planning: A Step-By-Step Approach

A reader writes in, asking:

“Can you describe exactly the steps you would take to determine whether a Roth conversion makes sense? I understand conceptually that they are advantageous when your tax rate is low, but can you elaborate on how exactly you would figure that out, as well as how to determine how large of a conversion to do?”

What follows is my process for retirement account distribution planning, including Roth conversions.

There are two broad stages to the process:

  1. Creating a “dummy” plan (or maybe you could call it a “default” plan), and
  2. Making improvements to that plan.

Making a Dummy Plan

By a “dummy” plan, I mean a plan in which every year you:

  • Do no Roth conversions.
  • Spend first from wages/earnings, required minimum distributions, Social Security, pension income, dividends/interest coming from holdings in taxable accounts, and only then from further distributions from tax-deferred accounts.
  • Take just enough out of retirement accounts in order to a) satisfy your RMDs and b) provide sufficient dollars to satisfy the desired level of spending, after considering taxes.

What we want to know is what your marginal tax rate (for ordinary income) would be in each of the next several years, under such a “dummy” plan. Note that we are concerned with your actual marginal tax rate, not just the tax bracket that you’re in.

The software I use for this process is Holistiplan, which I think is excellent, but it is priced based on the assumption that it’s being used in an advisory capacity for many clients rather than for an individual household. For most individuals doing DIY planning, a reasonable option is to use tax prep software to prepare hypothetical returns. (Note though that if you do not have experience preparing your own returns, there’s going to be quite a learning curve.) I sincerely do not think that a spreadsheet is a good tool for calculating your marginal tax rate, as it’s quite a challenge to create a realistic tax model that includes all the relevant factors.

For each year, you’re going to create a scenario/return in your tax modeling software, and then start recording the results in a spreadsheet.

For each year, see if you have enough after-tax income to satisfy your desired level of spending. (So this calculation is basically: wages/earnings, plus RMDs, plus Social Security/pension income, plus investment income from taxable accounts, minus taxes — and compare that to your desired level of spending.) If that level of income isn’t enough, increase tax-deferred distributions until it is enough. Remember, we are not yet including any further distributions from retirement accounts.

Then repeat the process for each of the next few/several years. (As I’ve mentioned previously, I don’t think there’s much value in going very many years into the future.) For each year, be sure to include any appropriate adjustments for changes in circumstances, such as:

  • The larger standard deduction for people age 65+,
  • Wage/self-employment income ending/declining due to retirement or partial retirement,
  • Social Security income starting, or
  • Selling your home.

If you’re married, it’s important to also run “only one spouse alive” scenarios under the dummy plan as well, to see what the marginal tax rate would be after one of the two of you dies.

Note that this whole analysis requires making some guesses and estimates. For instance, you’ll have to decide whether to assume the tax bracket structure is allowed to revert back to pre-Tax Cuts and Jobs Act levels at the end of 2025, or whether the current structure will be extended. And you’ll have to make assumptions as to portfolio performance, for the sake of determining RMDs.

Making Improvements to the Plan

With this “dummy” plan in place, take a look at how your anticipated marginal tax rate changes over time. A pattern that is very common for people in almost-retired or recently-retired scenarios is something along these lines:

  • Marginal tax rate falls once income from work stops,
  • Marginal tax rate increases once Social Security begins,
  • Marginal tax rate increases further once RMDs begin, and
  • (For married couples), marginal tax rate increases further once one of the two spouses dies.

From here, the goal is basically to “smooth out” your marginal tax rate. That is, we want to move income out of years in which you have a higher marginal tax rate and into years in which you have a lower marginal tax rate. The tools with which we can shift income from one year to another are:

  • Shifting income earlier by doing Roth conversions, or
  • Shifting income later by satisfying spending in earlier years via Roth accounts or liquidating taxable holdings with significant basis.

For years in which it makes sense to do Roth conversions, you have to decide how much to convert. To do this, first identify the next few thresholds (for the year in question) at which your marginal tax rate would increase. These could be the top of a tax bracket, an IRMAA threshold, the thresholds for Social Security benefit taxation, the bottom of the phaseout range for a particular deduction/credit, or the threshold at which the 3.8% Net Investment Income Tax kicks in.

Then determine exactly what your marginal tax rate would be after hitting that threshold. If that higher marginal tax rate is higher than the marginal tax rate you expect to face later, then you want to do Roth conversions up to (but not beyond) that threshold. If the marginal tax rate beyond that threshold is still below the marginal tax rate you expect to face later, then you probably want to do Roth conversions up to the next threshold. Of note, this is something of an iterative process, because as you do more and more conversions in the earlier years, it can result in your marginal tax rate in the later years being reduced (because RMDs will be smaller).

Retiring Soon? Pick Up a Copy of My Book:

Can I Retire Cover

Can I Retire? Managing a Retirement Portfolio Explained in 100 Pages or Less

Topics Covered in the Book:
  • How to calculate how much you’ll need saved before you can retire,
  • How to minimize the risk of outliving your money,
  • How to choose which accounts (Roth vs. traditional IRA vs. taxable) to withdraw from each year,
  • Click here to see the full list.

A Testimonial from a Reader on Amazon:

"Hands down the best overview of what it takes to truly retire that I've ever read. In jargon free English, this gem of a book nails the key issues."

My Plan for Asset Allocation/Spending in Retirement

A reader writes in, asking:

“Do you plan to switch to a different all in one fund when you get older? I have been doing the 3 fund portfolio over the last couple decades and was thinking of switching to all in one fund, but I would think that an 80/20 split for someone in their 50s is a bit aggressive. So do you plan to switch to a more conservative split later in life or do you plan to stay with this all in one fund until you retire?”

I’ve written before that I don’t necessarily plan to stick with this fund indefinitely. But that has more to do with costs (i.e., lower fixed-income yields and higher expense ratios) than it does with the fact that risk tolerance tends to decline with age. (Note: this dollar cost increases over time as the size of the portfolio increases. So what makes sense at one stage may not make sense at another stage, even if you appreciate the simplicity just as much as you always have.)

In other words, at some point I may switch to a three-fund portfolio — or a two-fund portfolio using Vanguard Total World Stock ETF for the stock allocation.

Ultimately though, the plan is essentially to segment the portfolio into two sub-portfolios as discussed in prior articles:

Let’s walk through a simplified example to show the idea works. Imagine that the following figures are applicable:

  • We anticipate total spending of $85,000 per year.
  • We anticipate the lower earner filing for Social Security at age 62, with a benefit of $20,000 per year.
  • We anticipate the higher earner filing for Social Security at age 70, with a benefit of $35,000 per year.
  • We are comfortable spending from a stock-heavy portfolio at a rate of 3% per year, and assuming that such would last more or less indefinitely.

Given the above figures:

  • From age 70 onward, we would need $30,000 per year from the portfolio (i.e., $85,000 total spending, minus $55,000 of Social Security). With a 3% spending rate, that would require $1,000,000. So we would need $1,000,000 allocated to the mostly-stock (or maybe all-stock) portfolio.
  • To retire at age 62, we would still need that $1,000,000 stock-focused portfolio, and we would need an additional $35,000 per year from savings for the years 62-69, because the larger Social Security benefit hasn’t begun yet. 8 x $35,000 = $280,000. So we would need an additional $280,000 allocated to something very safe (e.g., an 8-year CD ladder and/or TIPS ladder, perhaps with some I-Bonds in that mix).
  • And then for every additional year prior to age 62, we would need an additional $55,000 allocated to the safe investment mix (because neither Social Security benefit is being received at that point). For example if we wanted to retire at age 58, we’d have 4 years of $55,000 of spending from the safe-asset portfolio, followed by 8 years of $35,000 of spending from that portfolio. And the whole time, the remaining ~$30,000 would be coming from the stock-focused portfolio.

In other words, $500,000 in the safe-asset portfolio, plus $1,000,000 in the stock-heavy portfolio would let us retire at age 58, with a spending level of $85,000 per year. At the beginning, that’s a 5.67% spending rate from the portfolio. A lot of people would balk at that, especially beginning at age 58. But in terms of risk level, it’s mostly just the 3% spending from the $1,000,000 portfolio that generates much risk. The rest of the spending is coming from sources with very little risk (i.e., a combination of CD/TIPS/I-Bonds earlier, and Social Security later).

With regard to the 3% spending rate, I would likely be comfortable using a higher rate if stock valuations were lower or if we were talking about retirement at a later age. Also, I anticipate using something along the lines of a hybrid method in which the spending each year is an average of “last year’s spending plus inflation” and “x% of the portfolio balance” — as opposed to one or the other.

Retiring Soon? Pick Up a Copy of My Book:

Can I Retire Cover

Can I Retire? Managing a Retirement Portfolio Explained in 100 Pages or Less

Topics Covered in the Book:
  • How to calculate how much you’ll need saved before you can retire,
  • How to minimize the risk of outliving your money,
  • How to choose which accounts (Roth vs. traditional IRA vs. taxable) to withdraw from each year,
  • Click here to see the full list.

A Testimonial from a Reader on Amazon:

"Hands down the best overview of what it takes to truly retire that I've ever read. In jargon free English, this gem of a book nails the key issues."

Spending More Than 4% Per Year Can Be Safe

If you’ve read much about retirement planning, you’ve probably encountered the “4% rule” — the idea that, if you spend 4% of your portfolio balance in the first year of retirement, then adjust that level of spending upward each year in keeping with inflation, your portfolio will probably last through a 30-year retirement.

An unfortunate side effect of the proliferation of this concept is that people sometimes think that it’s automatically dangerous to spend more than 4% of your portfolio per year. In reality, there are plenty of cases in which spending more than 4% per year isn’t particularly risky — and even some cases where that’s the safest thing to do!

The “4% Rule” Often Involves Spending More than 4%

The idea of the 4% rule isn’t to spend 4% of the portfolio balance each year. Rather, the idea is to spend 4% in the first year of retirement, then adjust the dollar amount based on inflation going forward, regardless of how the portfolio performs.

As a result, even with the original 4% rule strategy, there are plenty of scenarios in which a person ends up spending more than 4% of the portfolio balance in a given year. (For example, any scenario in which the portfolio declines at all in Year One will result in spending more than 4% in Year Two.) Scenarios of that nature are already accounted for in the research that found that a 4% initial spending rate was reasonably safe.

Age Matters

Depending on your age, spending more than 4% per year can make perfect sense. As an obvious example, consider a 85-year-old widower. He doesn’t need his portfolio to last another 30 years. He might want to spend at a low rate, if his goal is to leave most of his savings to heirs, but he doesn’t have to.

Conversely, if you sell a business at age 35 and plan to be retired as of that point, living primarily off the portfolio, I would not suggest spending 4% per year. Given the super long time span that’s likely to be involved, it would probably be prudent to start with something more like 3% — or possibly even less.

Intending to Deplete the Portfolio

One long-time reader of this blog is unmarried, in her 60s, retired after a career with the federal government. Her home is paid off. And, in her own words, her savings are “modest, compared to what I would have tried to accumulate if I did not have a pension.”

Her plan is to spend about 10% of the portfolio balance per year, and I think that’s entirely reasonable. She plans to deplete the portfolio — that’s the goal. Spend the portfolio down while her health is still such that she can get the most enjoyment from the additional spending, and then live on the (not-at-all-trivial) pension for her remaining years.

Delaying Social Security

Finally, as we’ve discussed about a zillion times, delaying Social Security is typically advantageous for most unmarried people, for the higher earners in married couples, and in some cases even for the lower earner in married couples.

But delaying Social Security means spending down the portfolio at a faster rate in the meantime — often a rate in excess of 4%. And that scares some people.

But in reality, this is typically the safest thing to do.

You can carve out a separate chunk of your portfolio to satisfy the higher level of spending in early retirement, and put that money in something low-risk. (For example, build an 8-year CD ladder to satisfy the 8 years of higher spending until your Social Security kicks in.) In such a case, yes, you’re likely spending more than 4% in those years. But that chunk in question has almost no risk. And the result is a lower long-term spending rate once your Social Security does kick in. (Plus, in the event that you were to deplete your portfolio, you’d be left with a higher level of income than if you had not delayed Social Security.)

Retiring Soon? Pick Up a Copy of My Book:

Can I Retire Cover

Can I Retire? Managing a Retirement Portfolio Explained in 100 Pages or Less

Topics Covered in the Book:
  • How to calculate how much you’ll need saved before you can retire,
  • How to minimize the risk of outliving your money,
  • How to choose which accounts (Roth vs. traditional IRA vs. taxable) to withdraw from each year,
  • Click here to see the full list.

A Testimonial from a Reader on Amazon:

"Hands down the best overview of what it takes to truly retire that I've ever read. In jargon free English, this gem of a book nails the key issues."
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