Leaderboard

If the plan says the required beginning date is delayed until the year of retirement for non-5% owners age 70.5, then there is no RMD for this person until the year of retirement. The definition of required beginning date in 1.401(a)(9)-2 Q&A 2 does not take into account when distributions are received, it is based entirely on age, ownership, employment status and plan provisions. The statement in an earlier post here that a distribution to a currently employed non-5% owner after age 70.5 triggers an RMD is WRONG. So, 1. is no, unless the participant retires during the year. The EOB discussion you quoted deals with the treatment of distributions during the distribution calendar year if an RMD is required. In your case, that will only apply if the participant retires during the year. 2. The premise is wrong. Unless the plan says otherwise, the first distribution calendar year [1.401(a)(9)-5 Q&A 1(b)] for RMD purposes for this participant will be the year of retirement. No RMDs are required prior to the first distribution calendar year.

Kitces had a very good article about this last year.

Don't quit your day job! :-)