RMD from a terminating profit sharing plan

[Jakyasar]

Hi

My apologies if this was asked before/missed it.

PS plan terminating now. Have a 75 year old participant receiving RMD (none withdrawn for 2020 yet).

Because of the plan termination, do they need to receive the RMD or can waive it?

Thank you

[Lou S.]

Normally you would need to process the RMD. However for 2020 the CARES Act has eliminated RMDs for defined contribution plans so no you do not need to do an RMD for the partcipant this year.

[Jakyasar]

Thank you, will amend the plan prior to termination so that CARES will kick in.

[Larry Starr]

22 hours ago, Jakyasar said:

Thank you, will amend the plan prior to termination so that CARES will kick in.

It's appropriate to amend the plan, but just to make sure the plan doesn't still require a distribution even if there is no RMD distribution.  Assuming your plan doesn't require a distribution unless it is an RMD, then for 2020 the LAW eliminated RMDs so you aren't amending for that reason.