Cynchbeast Posted December 4, 2013 Posted December 4, 2013 Non-owner participant is age 89 and retiring this week. He has money in 401(k) and IRAs. 1) After separation from service, must he start RMD from his 401(k) in 2013 or 2014? 2) Can he take some of his IRA RMD from the 401(k)?
MoShawn Posted December 4, 2013 Posted December 4, 2013 1) First distribution calendar year is 2013. He must receive the first RMD by 4/1/14. If he delays into 2014, he would need to take a second RMD by 12/31/14 for 2014. 2) No. You cannot mix RMD's from an IRA with a 401(k).
BG5150 Posted December 4, 2013 Posted December 4, 2013 Nor can you combine 401(k)s. Each qualified plan stands on its own for RMD purposes. ETA Consulting LLC 1 QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
Cynchbeast Posted December 4, 2013 Author Posted December 4, 2013 He intends to rollover his 401(k) into an IRA before the end of this year. Since his first RMD is not due until 04/01/14, can he rollover his entire 401(k) balance now and forget its RMD, or must he take the RMD first before rolling the remainder over?
BG5150 Posted December 4, 2013 Posted December 4, 2013 No. The first distributions from a 401(k) plan in any RMD year must be the RMD. QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
david rigby Posted December 4, 2013 Posted December 4, 2013 No. The first distributions from a 401(k) plan in any RMD year must be the RMD. ... and is not rollable. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
GMK Posted December 5, 2013 Posted December 5, 2013 No. The first distributions from a 401(k) plan in any RMD year must be the RMD. Read this well-stated, concise sentence carefully. (It would not be an "RMD year" if he were still an employee.)
My 2 cents Posted December 5, 2013 Posted December 5, 2013 While it is true that it would not be an RMD year if the participant were still an employee, the original post said that the participant was retiring "this week". Presumably, that would mean that the participant ceased to be an employee during 2013, making 2013 the first RMD year. If the participant elects a lump sum distribution, it appears from the above posts that some of it would have to be treated as RMD and not rolled over. As I understand it, if the lump sum is not paid until 2014, presumably two years' worth of RMD (the amounts that would otherwise have had to be paid for 2013 by 4/1/14 and the amount that would otherwise have had to be paid for 2014 by 12/31/14) would have to be carved out from the rollover. Always check with your actuary first!
GMK Posted December 5, 2013 Posted December 5, 2013 ^ I agree. Just emphasing to general readers that it has to be an RMD year before there's an RMD. No RMD if still an employee. Can be confusing.
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