Required Beginning Date for RMD

[mming]

A >5% owner attains age 70 1/2 on 12/28/11, so it appears that the RBD for his RMD will be 4/1/12. His advisor, however, insists that there's an exception for participants who are born in the latter half of June, i.e., he wouldn't be considered attaining 70 1/2 until 2012, and therefore his RBD isn't until 2013. We were not able to find such a provision after looking through both IRC 401(a)(9) and Treas. Reg. 1.401(a)(9)-2. The Treas. Reg. even had the example of someone who was born on 6/30/33 having an RBD on 4/1/04. The advisor's belief seems unfounded - has anybody ever heard of such an exception?

[Bird]

That's a shame (that you did any research on this). Nutty stuff like this, you need to ask the person making the claim to provide the cite.

[Tom Poje]

I'd ask them if 1.401(a)(9)-2 Q-3 has changed.

...if an employee's DOB is June 30, 1933 the 70th anniverasry is June 30,2003. Such employee turns 70 1/2 on December 30,2003...RBD is April 1, 2004.

(I need a new copy if it has changed)

[masteff]

One thing similar that comes to mind is in the half-month convention in depreciation accounting which says an asset is placed in service only if it's on or before the 15th of the month. Perhaps he's just crossed a wire?