RMD Determination

[Reggie]

Hello,

What would be deemed the RMD for a participant from a DB plan, Age 79, who is receiving $2,948.26 in the form of a Life with 5-year Certain annuity, and, who also receives a single sum distribution of $43,342.26 as catch-up payment for underpayments in the past, all in the same calendar year 2023? One issue at hand is, if he is allowed to roll over all or part of the single sum that he is receiving?

Your response will be greatly appreciated.

Thank you.

[bito'money]

Is $2,948.26 the monthly amount he would have received if the 5-year C&L annuity started on his required beginning date, and is the $43,342.26 single sum simply the make-up annuity payments (with interest on the retro payments from required beginning date to the annuity commencement date)? (Since you didn't say, when was this person's required beginning date?) 

If so....the deemed RMD (subject to excess accumulation excise tax in each year from the year containing the required beginning date until 2022) would be 9-months of payments for the year containing his required beginning date, and, assuming the required beginning date was not 4/1/22, it would be 12-months' worth of payments for each subsequent year until the end of 2022. The RMD for 2023 would be equal to the 12 months of the annuity payments for 2023. Since the lump sum is to make up for annuity payments that were supposed to have been received from required beginning date until the benefit commencement date and that would not have been eligible for rollover in the first place, none of that lump sum amount would be eligible for rollover.