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Posted

Has anyone given any thought or seen any guidance related to the definition of "retire" for purposes of delaying required minimum distributions? We've just discovered an individual who is only working a handful of hours per year, but has never been formally terminated under the payroll system, so has not yet started RMDs.

Posted

I just got a stupid checklist comment from an IRS reviewer who requested that "retired" be substituted for "terminated employment." The client was willing to suffer fools, so I amended the terms, but I informed the IRS agent that the amendment also included a definition of "retirement" to mean "termination of employment after age 70 1/2" because the plan did not otherwise use the term and nothing in the law defined retirement despite the IRS having authority and many years to do so.

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