Do corrective ACP refunds offset MRDs?

[Guest TaxedToDeath]

If an HCE receives a refund due to a failed ACP test, and that HCE is receiving age 70 1/2 minimum required distributions, does the amount of the ACP refund reduce the amount of the MRD that must be taken?

[movedon]

Nope.

[Guest PiggyBank]

If an HCE receives a refund due to a failed ACP test, and that HCE is receiving age 70 1/2 minimum required distributions, does the amount of the ACP refund reduce the amount of the MRD that must be taken?

See Treas. Reg. §1.401(a)(9)-5, Q&A-9(b)(3), which states that corrective distributions of excess contributions and excess aggregate contributions cannot be taken into account in determining whether the minimum required distribution has been distributed in a calendar year. ACP refunds therefore do not reduce the amount of the MRD.

[Guest TaxedToDeath]

Thanks to both of you for your help!