$200 withholding rule

[BG5150]

For the $200 withholding threshold, does that include all distributions in a year? Or just those eligible for rollover?

For example, a participant's RMD for 2010 is $150. If that person took a $150 RMD in May, and later took a $150 in-service distribution (now eligible for rollover), am I over the $200 mark?

[GMK]

If I may add a tag-along question,

is there an official cite/statement about the $200 threshhold that doesn't tie it to "in lieu of partial shares"?

[masteff]

For the $200 withholding threshold, does that include all distributions in a year? Or just those eligible for rollover?

For example, a participant's RMD for 2010 is $150. If that person took a $150 RMD in May, and later took a $150 in-service distribution (now eligible for rollover), am I over the $200 mark?

My CCH "US Master Pension Guide" says: In determining whether the $200 floor is reached, all eligible rollover distributions made to a recipient by a plan within one tax year must be aggregated.

I'd say don't aggregate in your example since the MRD is not an eligible rollover distribution.

@GMK - my 2002 guide cites IRS Reg 31.3405©-1 Q&A-14 (I didn't go look it up to see if it mentions "in lieu of" or not)

[GMK]

Hooray for masteff, and thank you.

It does not mention "in lieu of" at all. (Sorry about my giddiness, but I now have the answer to the first BenefitsLink question I posted .. a long time ago.)

BYW, BG, Q & A-14 says that you have aggregate eligible rollover amounts during the year, but it does not mention distributions that are not rollover eligible, which puts me in agreement with masteff's reply.