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EGTRRA/Top Heavy & look back for In-Service Withdrawals


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Looking at the In-Service Distribution issue with respect to the 4 year look back. Does the participant's status as of the Top Heavy Determination date have any effect.

Example: 12/31/01 Determination date for 2002. Participant terminated in 2000 but had made In-Service Withdrawals of $1,000 for each of 1997, 1998, 1999.

Q1-Can those withdrawals be ignored?

Q2-Are Required Minimum Distributions considered "In-Service Withdrawals"?

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