RMD Distribution

[mjf06241972]

Can a refund resulting from a failed ADP test be used to satisfy RMD requirements for Key Employee in a 401k Plan?  

Thanks.

[ESOP Guy]

No

Here is cite:

 

[Tom Poje]

now I feel like a kid

"Made you look"

another cite would be from the min distr regs

1.401(a)(9)-5 Q/A9 (b) exceptions The following amounts are not taken into account to determine if a min distrib has been made

(3) Corrective distributions of excess contributions.

by the way

(1) is deferrals returned because of 415 limits

(2) is return of excess deferrals

(4) is deemed distributions of loans