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Posted

I've been driving myself crazy on this. Question came up as to whether an in-plan Roth conversion/rollover could satisfy the RMD requirements. I know it can't, but I'm having a devil of a time finding "proof" - and I'm sure it is staring me in the face! I recalled that there was guidance a long time ago where it said that for 401(a) purposes, an in-plan rollover was not a "distribution." So I looked back at IRS Notice 2010-84, etc., etc., and while I found SOME of what I was looking for, I couldn't find anything that confirmed this head-on -  (or possibly my eyes scanned over it). Anyone recall the citation for this? There's ample IRS verbiage out there that addresses this in an IRA context, but seems to be a dearth of similar IRS publications answering this same question for designated Roth accounts.

Shoulda stayed in bed this morning...

Posted

Thanks Lou. Yeah, I know RMD's are not eligible for rollover. The assertion was made that since the conversion is taxable, the taxable amount would represent a "distribution" from the plan. I know this is wrong - but this is the piece I'm trying to "prove" - that it is not, in fact, a distribution from the plan for 401(a) purposes.

Posted

Not a cite, but if that line of logic were accurate, there would be no such thing as an RMD from a non-converted Roth 401(k) elective deferral balance because the entire account would have been "distributed" (albeit a little bit at a time) immediately upon deferral. 

Or, for a more extreme example, a participant has a $100,000 pre-tax balance in 2021 and will reach 72 during 2022. If they do an in-plan conversion of all $100,000 during 2021, would this person take the position in 2022 that no RMD is ever required because the entire account had been distributed by 12/31/21? If so, not sure any cite will help. 

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