RMD required when transferring between employers in a MEP?

[C. B. Zeller]

Company A sponsors a MEP with unrelated company B adopting. During 2018, participant X, who is a non-owner employee of company A and over age 70.5, transfers to company B, .e.g they are terminated from company A and hired by company B. Is this person required to take an RMD by 4/1/2019?

[Luke Bailey]

I'll be interested in seeing what others have to say, but I think you may need to request a PLR from IRS to know answer to this one. 1.401(a)(9)-2, Q&A-2(a) says the RBD under the retirement alternative is when the employee "retires from employment with the employer maintaining the plan." So the premise is that there is a single employer, i.e., "the" employer. I think you could argue it either way, both technically and on policy grounds.

[C. B. Zeller]

Thanks for the reply. It turned out that the employee actually terminated employment with B before the end of the year, so that answered the question for us. I am still curious to know though if there is a definitive answer in the original situation.