AlbanyConsultant Posted April 25, 2018 Share Posted April 25, 2018 I've got a participant in a plan with deferrals, safe harbor, profit sharing, and merged old money purchase money. The participant is an owner and needs an RMD this year. Can he opt to have his RMD come from his profit sharing 'portion' and therefore avoid the QJ&S hassle? If he can do that and then move to deferrals and safe harbor, that should buy about two or three years, and I'm hoping he retires by then and takes it all (yes, I know he'll have to do the QJ&SA mambo at at that point, but at least it's only once). Thanks. Link to comment Share on other sites More sharing options...
Mike Preston Posted April 25, 2018 Share Posted April 25, 2018 Yes, unless plan documentation requires a different result. Link to comment Share on other sites More sharing options...
JamesK Posted April 26, 2018 Share Posted April 26, 2018 On 4/25/2018 at 1:54 PM, Mike Preston said: Yes, unless plan documentation requires a different result. See the special rules in Treas. Reg. 1.401(a)(9)-8, Q&A 2 and 3 for the details confirming Mike Preston's response. Link to comment Share on other sites More sharing options...
AKconsult Posted May 15, 2018 Share Posted May 15, 2018 QJSA notice and consent requirements do not apply to RMDs, even when taken from a MP plan. See https://www.irs.gov/retirement-plans/qualified-joint-survivor-annuities-in-money-purchase-plans Link to comment Share on other sites More sharing options...
AlbanyConsultant Posted May 17, 2018 Author Share Posted May 17, 2018 I was not aware of that exception. Thanks, AKconsult! Link to comment Share on other sites More sharing options...
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