RMD

[PS]

Hi, 

I wanted to ask on a  401k distribution related to a plan termination and the RMD.  One of the participant was informed that a RMD was processed for 2023 and he could need to take the RMD for 2024 before he did a rollover.  This participant was still actively working on 12/31/2023 although the Plan termination date was 12/31/2023. 

• Does the IRS allowance still hold if one is working full time and not terminated from employment will require to take the RMD? Though the Plan termination date is 12/31/2023.
• If, with the plan Termination date all participants needs to be terminated, is it possible to correctly have a 2024 termination date? Therefore the participant can take the RMD for 2024 and not for 2023?
• Or, does the Plan termination date supersede the IRS allowing an individual not to take the 401k RMD in 2023 if still employed, while still meeting the direction to take the 401k distribution and RMD for 2024 by April 30, 2024? 

Thanks

[CuseFan]

If the person is not a 5% owner then their required beginning date is generally based on the later of the applicable age or their actual retirement. Plan termination prior to one's retirement does not trigger an RMD based on age alone. BUT, consult the plan document as some plans (but not many) base their RMDs on age alone without consideration to retirement whether or not a 5% owner.

and it's 4/1, not 4/30