RMD from 401k with Roth and Traditional

[Dougsbpc]

Have a 401(k) plan where the 100% business owner did a Roth conversion back in late 2011. He now has a Roth account and a traditional account under the plan. His required beginning date is 4/1/17 but he wants to take RMDs in 2016.

My understanding is that:

1. We calculate the RMD separately for each account.

2. He can take each portion at different times during 2016 as long as the total of each is taken by December 31, 2016.

3. The 5 year requirement is waived for his Roth portion because that consists entirely of his conversion.

Does anyone agree / disagree with the above?

Thanks.

[GMK]

Just curious, where did you read that the 5 year requirement (for qualified distributions, I presume) is waived for the Roth portion? Thanks.

[Lou S.]

Just curious, where did you read that the 5 year requirement (for qualified distributions, I presume) is waived for the Roth portion? Thanks.

It's not waived. I think he means the 5 year requirement has been satisfied since the conversion was in 2011, then 2011 was year 1, 2015 was year 5.

[Tom Poje]

what I understand (and the ERISA Outline Book 6 section VII D.2e6 says

"Thus the Value of the Account Balance will include the designated Roth account"

so there would be no need to calculate an RMD separately. (If it is a Roth IRA then there is no minimum distribution)

so you take Value of the Account Balance and divide by the proper factor and that is the min distribution.

I don't think there is a requirement you then have to then pro-rata the amount from Roth and other sources, but obviously the tax consequences are different depending on which sources you take it from.