Scuba 401 Posted November 1, 2017 Posted November 1, 2017 Due to hurricane participant takes 2017 RMD in January of 2018. they were given until january 31 under the hurricane relief. which tax year is it included for, 2017 or 2018?
ETA Consulting LLC Posted November 1, 2017 Posted November 1, 2017 2018 Good Luck! CPC, QPA, QKA, TGPC, ERPA
Scuba 401 Posted November 1, 2017 Author Posted November 1, 2017 are you sure. i would have bet 2017.
My 2 cents Posted November 1, 2017 Posted November 1, 2017 I would have expected it to be the tax year in which the payment was made (if different from the tax year for which the payment was made). I presume that, for participants newly subject to RMDs, the payment by April 1 of the year after the year of the RMD would invariably be declared as taxable in that following year (assuming that the payment or payments were made between January 1 and April 1 of that following year). Why should this situation be treated differently? Always check with your actuary first!
Tom Poje Posted November 1, 2017 Posted November 1, 2017 I know hurricane relief provided for easing rules on hardships distributions and loans, and filing deadlines for the 5500. and minimum funding as well, but I don't recall the combination of minimum funding and hardship distribution and applying it to minimum distributions nor did I see it listed under the 2 announcements I looked at. in fact, the relief is to take a loan by 1/31/18 or a hardship by that date which would be an additional type of distribution one could request. I don't understand why taking a required minimum distribution would be delayed to that date as well, but maybe I missed something. or haven't been able to find it in any search I just did.
Scuba 401 Posted November 1, 2017 Author Posted November 1, 2017 1 minute ago, Tom Poje said: I know hurricane relief provided for easing rules on hardships distributions and loans, and filing deadlines for the 5500. and minimum funding as well, but I don't recall the combination of minimum funding and hardship distribution and applying it to minimum distributions nor did I see it listed under the 2 announcements I looked at. in fact, the relief is to take a loan by 1/31/18 or a hardship by that date which would be an additional type of distribution one could request. I don't understand why taking a required minimum distribution would be delayed to that date as well, but maybe I missed something. or haven't been able to find it in any search I just did. its not in the specific announcements. it is incorporated by reference in 7508A which lists all the relief that is granted in a disaster declaration. also see asppa bulletin no. 17-10.
ETA Consulting LLC Posted November 2, 2017 Posted November 2, 2017 10 hours ago, Scuba 401 said: are you sure. i would have bet 2017. I just don't see why a distribution would be taxed in any year other than the year it was received. RMDs merely deal with when a distribution must be taken from the plan; this says nothing about taxation. Under what authority would there be a tax on a distribution that has not been taken. So, if the distribution is actually taken in 2018, then that is when it would be taxed. Good Luck! K2retire and Bird 2 CPC, QPA, QKA, TGPC, ERPA
Mike Preston Posted November 10, 2017 Posted November 10, 2017 I agree it would be taxed per 2018. But I wonder if a plan participant eligible for Congressional disaster relief could insist on a hardship withdrawal that would be eligible for taxation spreading over three years?
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