QLAC Annuity

I think a distribution from a QDPA, provided the distribution is an eligible rollover distribution (e.g., a cash surrender amount) can be rolled into an IRA regardless of 415. See Treas. Reg. Section 1.402©-2 Q&A-10(b).

In addition to waiving 2009 participant RMDs, 401(a)(9)(H) also changed the RMD rules for beneficiaries under the life-time annuity rule and 5-year rule. Can anyone cofirm the following points? With respect to participants who died in 2008, beneficiaries have one additional year, until Decemebr 31, 2010, to elect the life-time annuity rule. For participants who died in 2004 through 2008, the 5-year rule is extended by one year (e.g., for a participant who died in 2004, beneficiaries must complete distributions by Decemebr 31, 2010). The 2009 RMD waiver has no effect with respect to participants who died in 2009.