ratherbereading Posted October 24, 2022 Posted October 24, 2022 Plan year end is 09/30/2022. Funds at Nationwide. Are RMDs done based on 12/31/2021 balance or the 09/30/2021 balance? Thanks in advance! 4 out of 3 people struggle with math
Peter Gulia Posted October 24, 2022 Posted October 24, 2022 If you’re asking what the plan provides, Read (and interpret) The Fabulous Document. A typical IRS-preapproved document partially paraphrases and refers to the tax-law rules, including 26 C.F.R. § 1.401(a)(9)-5. https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR6f8c3724b50e44d/section-1.401(a)(9)-5 That rule looks to “the account balance as of the last valuation date in the calendar year immediately preceding that distribution calendar year[.]” Q&A-3(a). If the plan has valuation dates quarter-yearly or more often, it seems likely a December-close date fits that description. CuseFan, Riley Britton, Bri and 1 other 3 1 Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
MWeddell Posted October 24, 2022 Posted October 24, 2022 Given that the April 1 and December 31 dates in Code Section 401(a)(9) don't depend on the plan year, I would be much surprised if any plan document provided for different dates merely because the plan year is not the calendar year. Bri and Riley Britton 1 1
Popular Post Lou S. Posted October 24, 2022 Popular Post Posted October 24, 2022 4 hours ago, MWeddell said: Given that the April 1 and December 31 dates in Code Section 401(a)(9) don't depend on the plan year, I would be much surprised if any plan document provided for different dates merely because the plan year is not the calendar year. Pooled non-calendar year profit sharing plans are often valued annually on the last day of the plan year. The 401(a)(9) regs address this. You take the balance on the valuation date, add in in contributions from the valuation date to 12/31, subtract distributions from the valuation date to 12/31 and that is your adjusted 12/31 balance for figuring out next year's RMD. Bill Presson, ERISAGirl, jsample and 2 others 5
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