Will rollover from IRA to DC Plan cause RMDs to cease if participant is still employed?

[Guest oxdougw]

A participant who is over 70-1/2 and is still employed has delayed RMDs from the plan until termination of employment. However he has an IRA that he's been getting RMDs from.

He'd like to roll that IRA into the DC Plan. Would he then be able to cease and delay the RMDs from the amount rolled in? If the answer is yes, what reg can I print to support the finding?

Thanks

[Harwood]

Of course the entire RMD regulations are in § 1.401(a)(9).

I sum it up thusly: wherever the money is December 31, that is where the next RMD must come from.

If all the money is in a Qualified Plan where a non-5% owner continues to work, the Required Beginning Date is not triggered, so no RMD. This includes money rolled into the plan from other sources.

[Guest oxdougw]

I agree with you there. If money was in the IRA on 12/31, then an RMD must be issued for the IRA.

But if the money is rolled this year into a qualified plan, our take on it is that qualified plan rules then apply and RMDs can be delayed until the non-5% participant quits.