Dobber

@justanotheradmin Exactly. It's not a rollover in the traditional sense but the distribution can be repaid/"re-contributed" - another term for a rollover. I am struggling with the taxation piece of the equation For example, a qualifying individual takes a $100,00 "CRD" and subsequently rolls it in IRA on or before 12/31/ 2020. Is the distribution included in 2020 income? Or is the otherwise taxable income offset by the "rollover" Maybe I am just overthinking this however I've received a few inquires - looking ensure that I am providing accurate information. Thank you

@EBECattyI came here to post a question along the line your original "post. Can a "qualifying individual" take a CRD from his/her 401(k) and subsequently roll it into a traditional IRA thus avoiding taxes? Would the RK send the proceeds (via direct rollover) to an IRA custodian? Or does the check (wire) have to be sent to the individual? PS I understand the rule allows the income taxes to paid over 3 years - in this scenario the individual would be doing a tax-free(?) IRA rollover in the same year. I'm thinking participants (Whose plans don't offer in-service) distributions are looking for a workaround - ultimately getting the money into a IRA All assistance is appreciated.

What is the effective date for the new post-death payout rules for 403(b) and 457 plans? The Secure Act reference's gov't plans have a delayed effective date of 1/1/22 - but I've seen this (delay) date applies to Section 414(d) plans and 403b/457 plans Which is correct? Also, assume the delay applies to 403(b) plans - I would venture it only applies to gov't sponsored 403(b) plans (i.e. school districts?) Thank you

Post Secure - an IRA inherited by a non EDB is subject to a 10-year payout. Pre-Secure - an IRA inherited by a DB can stretch based of their life-expectancy All successor beneficiaries that inherit an IRA on or after 1/1/2020 are now subject to the 10-year payout Question: Does the 10-year payout start fresh upon an successor beneficiary inheriting? Or.. does the (beneficiary of the beneficiary) only eligible for what's left of the original beneficiaries 10-year payout?

Can you confirm this new provision applies to IRAs too? I think it does however it was not mentioned in any of the replies Also, I am hoping someone can add some clarification to the "repay" provision - 1. What is the timing to repay the distribution? 60 days? 2. Does the distribution have to repaid to the same plan/account it was distributed from? 3. does the "repayment" get deposited as after-tax dollars? Or do we need to wait for the IRS to issue regulations? Thank you

If a small business has an existing 401(k) but then sets up a cash balance plan, could they use the tax credit for the cash balance plan? Is the tax credit per employer or plan? Thank you

What does everyone thing of the following idea? Would it work? A lot of clients are in the enviable position of not needing the income from the RMDs. Therefore they are continually looking for ways to defer or reduce minimum distributions. Let's say a client, age 73, retires from his company in 2019 Prior to rolling the assets to an IRA he takes his 2019 401k RMD. He wont be subject to an IRA RMD until 2020. Later in 2019, he sets up his own business (consulting, Uber Driver, app developer, etc) and establishes a one-person 401k and subsequently rolls his IRA in the newly established 401(k). It would appear to me that the owner (even though they own more than 5% of the business) would not be subject to RMDs until they separate from service I believe this to be true due to section 401(a)(9)(C)(i)(l) "in the case of an employer is a 5% owner with respect the plan year ending in the calendar year in which the employee attains age 70 1/2...." In other words it seems language does not require for an ownership test each year Thoughts?