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Guest PGH.ERISA
Posted

Employee leaves employer at age 72 in early 2008 to go to work for a new employer. Employee wishes to make a direct rollover from the old employer's DC plan to the new employer's DC plan. It seems clear that the rollover amount cannot include the RMD amount for 2008, because the employee is considered to have retired from employer #1. If employer #2's plan does not require distribution until the later of termination or 70-1/2, must the employee receive any RMD payments during employment with employer #2? (i.e., can the rollover to a new paln protect the employee from receiving RMD payments that he would have received if he had left the money in employer #2's plan?) I believe the answer is that no payments should be required under employer #2's plan, but I have not found anything definitive so far.

Guest PGH.ERISA
Posted

I have subsequently found PLR 200453015, which is not 100% on point (it deals with a 5% owner of one company who rolls over money from company 1's plan to a plan of a company in which he is not a 5% owner, thereby delaying required distributions because the transferred funds become subject to the RMD rules of company 2), but which clearly indicates that the RMD rules of the transferee plan will apply, and that no further distributions will be required until after the employee leaves the new employer. It would still be helpful, however, to find something out there that matches my specific situation.

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