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Posted

If a participant that is required to take an RMD and wants to roller over a large portion of their account balance to an IRA, can they do this and take the plans required RMD out of that IRA account to cover the amount of the RMD due from the plan?  They want to make the whole RMD as a charitable donation, would this be allowed as the donations they want to make will be larger than the allowable amount to process from the plan as the donation?  Or is there any other ways around it so they can make the donations they want to make?

Posted

No. The plan is required to make the RMD and such portion of any larger lump sum is not rollover eligible. So if lump sum was $100,000 and the RMD portion was $20,000 then only the non-RMD portion of $80,000 may be rolled over. What the IRA owner does with the $80,000 IRA in terms of future RMDs/charitable donations is of no concern to the plan.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

Posted

but if the holder is over 70-1/2(not affected by the SECURE Act), he can make a Qualified Charitable Distribution from the IRA, have it count as part of his RMD from the IRA, not have it included in either his Modified Adjusted Gross Income (which is used to determine his Medicare premium in 2022) or in his taxable income for 2020..

Posted
22 hours ago, Kal said:

he can make a Qualified Charitable Distribution from the IRA, have it count as part of his RMD from the IRA

yes, but he cannot get his RMD from the 401k plan into the IRA, the 401k plan must make its own RMD to the participant which is not rollover eligible in any fashion

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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