sam2012 Posted June 10, 2016 Posted June 10, 2016 Participant is 70 1/2 and in 2016 took an in-service 6 figure distribution that rolled to an IRA. Account balance was $0.00. Participant continued working and contributed a few thousand dollars and then terminated all in 2016. Participant now wants remainder of money to put into IRA. Does the remaining funds need to entirely be paid as a RMD to partially satisfy RMD based on 12/31/15 or can this be rolled over and entire RMD handled from IRA? Participant is aware that additional funds need to be taken from IRA to satisfy minimum based on 12/31/15.
GMK Posted June 10, 2016 Posted June 10, 2016 Once a participant is required to take RMD's, the first portion of a distribution is deemed to be RMD until the RMD amount for the year is satisfied, so I'd pay out the remaining funds from the Plan as RMD and inform the IRA of how much of the RMD is left to be distributed from the IRA, that is, how much of the previous rollover has become not eligible for rollover because of the termination of employment and age. Based on previous postings, others may say just roll it over and let the participant get it all back from the IRA, but that's not my understanding of how it works.
BG5150 Posted June 10, 2016 Posted June 10, 2016 Also, the plan had an operational error, so they should put in procedures to avoid this in the future. QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
ESOP Guy Posted June 10, 2016 Posted June 10, 2016 Also, the plan had an operational error, so they should put in procedures to avoid this in the future. Unless the sponsor can use the psychic hotline to know this person was going to terminate after the in-service distribution I am not sure what that procedure would look like. K2retire 1
GMK Posted June 10, 2016 Posted June 10, 2016 ^agreed. The initial rollover was OK, because the participant was still employed at the time and did not have a required beginning date when the distribution was made.
BG5150 Posted June 10, 2016 Posted June 10, 2016 Also, the plan had an operational error, so they should put in procedures to avoid this in the future. Unless the sponsor can use the psychic hotline to know this person was going to terminate after the in-service distribution I am not sure what that procedure would look like. True. I missed the part about in-service. Must be the Friday morning reading comprehension lapse... ESOP Guy 1 QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
GMK Posted June 10, 2016 Posted June 10, 2016 You're way ahead of me if yours are only on Friday mornings.
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