RMD and asset acquisition

[R. Butler]

Co. A acquires Co. B in an asset acquisition in November 2015. Co. B sponsored a plan, but the plan was terminated at acquisition. Some participants did roll their balances into Co. A, but rollovers didn't actually occur until January and February of 2016.

Bob was 72 at the time of the acquisition, but still employed. He terminates in July 2016. A couple of RMD issues:

1. It is my understanding that there would not be a 2016 rmd for Bob. He did not have a balance in Co. A's plan at 12/31/15.

2. Should have Co. B's plan issued an rmd for 2015? My understanding is yes because the employer changed at Co. B's acquisition.

Thanks in advance for any guidance.

[Bill Presson]

I agree with your assessment. As soon as the transaction took place, he no longer worked for Co. B and that triggered an RMD.