Basically Posted December 23, 2021 Posted December 23, 2021 If a participant in a plan is not an owner, do they have to take an RMD? Wasn't that the way it was in the beginning? Only owners had to take an RMD, non-owners didn't have to take an RMD from a qualified plan? Thanks
John Feldt ERPA CPC QPA Posted December 23, 2021 Posted December 23, 2021 Is this non owner still working for the employer/plan sponsor? Are they an indirect owner through attribution?
Basically Posted December 23, 2021 Author Posted December 23, 2021 No relationship at all the the owner. Still employed and working. As I recall, that is the key.. "still employed". Right?
John Feldt ERPA CPC QPA Posted December 23, 2021 Posted December 23, 2021 Yes, you’re rounding third now and almost home. The regulations do not require the RMD, but you now have to read the fabulous plan document. And also check to see if, perhaps, they started RMDs in a prior year already. Luke Bailey 1
Basically Posted December 23, 2021 Author Posted December 23, 2021 Doc says... Required Beginning Date for a Participant other than a More Than 5% Owner - "Later of age 70-1/2 or retirement" So she is good... no need for an RMD. Looking at the document, there is an option that could have been made when setting up the plan... "election of later of age 70-1/2 or retirement" . Is that to mean that what the doc says now shown above does not allow a participant to take an RMD until they retire? Even if they are old enough for an RMD? The "election of" option would be the most flexible option.
John Feldt ERPA CPC QPA Posted December 25, 2021 Posted December 25, 2021 Seems like that’s what it says. You can always check with your document provider, of course.
Bri Posted December 27, 2021 Posted December 27, 2021 Sometimes plans will allow in-service distributions, and a subset of those will allow them specifically/solely for RMD purposes. That could open up the opportunity to withdraw at least an RMD amount if not more.
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