RMD for not quite terminated employee

[BH1528]

There is an employee who has an accrued benefit who is over 70.5 and works seasonally. The company does not usually know if he will be coming back for the next year until ~March or April. He has not resigned from the company or retired but doesn't work the last few months of the year. Should he begin receiving an RMD?

[ESOP Guy]

Here is a link to a discussion of if a person worked the last day or not. 

I offer this because to me the question is really is this person terminated in 2018 or not or put another way are they an employee on the last day or did they term before that date.   This discussion gets into the idea when does a person terminate.  I hope it helps but it might not. 

 

Since I am a DC person and this is a DB plan I am willing to be told there is something about DB plans that changes this.  But I think the answer is the employer needs to decide is this person an employee currently or not 

[Luke Bailey]

IRS has never defined "retired" for this purpose, so facts and circumstances. You say he has not retired, so maybe no RMD. Would need to know more facts and circumstances.