RMD under 5-Year Rule

[GMK]

On page 4 of this article:

http://www.davis-harman.com/pub.aspx?ID=VFdwWmVnPT0=

is the statement that:

"If the 5-year rule applies, no amount is treated as an RMD that is ineligible for direct rollover for the first four years after the employee’s death, and no amount is eligible for rollover on or after January 1 of the fifth calendar year following the year of the employee’s death."

Do you know of any cite or reference that confirms that this is true? Thanks.

[Belgarath]

Yeah, I think this is correct. Take a look at 1.401(a)(9)-7, Q&A-3. Since under the 5-year rule, the entire balance must be distributed by the end of the 5th year, as soon as you start the 5th year, that is a "distribution calendar year" - and since the entire benefit must be distributed by the end of that year, there is no amount that would be an eligible rollover distribution 'cause it is ALL RMD.

[GMK]

Arrgh, the distribution calendar year, is it? That makes total sense, both for the first 4 years and the 5th year.

Thank you very much. Tell them to give you a raise.

[Belgarath]

ARRRRRRR, if I do that that, they will raise the Jolly Roger and keelhaul me. But thanks for the suggestion, matey. Draw yourself an extra ration of grog.

Bosses are like Long John Silver's parrot - "They lives forever, mostly, and if anyone has seen more wickedness, it is the Devil himself."