age 70 1/2 distribution & furlough status

[alexa]

We had a bunch of furloughs late last year

These employees have recall rights for 3 years.

For those that are over age 70 1/2, are they required to get a minimum distribution

distribution by 4/1?

Active employees over age 701/2 are not required to take a minimum distribution from our plans.

I see this as a grey area. Is anyone aware of any guidance out there where it defines what "terminated"is?

Thanks

[Guest Jeff V]

We, too, had a lot of furloughs with recall rights in 2001. We treated furloughs as terminations to the extent they were permitted to take distributions. I honestly don't know of any guidance, but we've applied the "termination" theme consistently so we would distribute 401a9 distributions for this group.

Seems it was simpler when "separation from service" was the standard than now with "termination of employment" for this purpose.