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401(a)(9)© defines RBD. And since 416 defines ownership including the 318 attribution rules, as you have referenced, then the parents are 5% owners. So, they have to take RMD's even though they are still working. © Required beginning date.— For purposes of this paragraph— (i) In general.— The term “required beginning date” means April 1 of the calendar year following the later of— (I) the calendar year in which the employee attains age 701/2, or (II) the calendar year in which the employee retires. (ii) Exception.— Subclause (II) of clause (i) shall not apply— (I) except as provided in section 409 (d), in the case of an employee who is a 5-percent owner (as defined in section 416) with respect to the plan year ending in the calendar year in which the employee attains age 701/2, or (II) for purposes of section 408 (a)(6) or (b)(3).