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Posted

I just like to be 100% because RMDs are critical as you know given the potential penalty.  

Participant has pretax and Roth in a 401(k) plan and is required to take RMD now in 2023.  The RMD is based on the account value in total - but I think the participant may allocate the RMD between pretax and Roth as they choose? 

Thank you 

Posted

Is that a question or a statement?

FWIW, I believe the participant can choose any combination of Traditional or ROTH to satisfy the RMD requirement inside a Plan prior to 2024 as the Plan has the RMD requirement and there is no mention of individual sources having to independently satisfy the RMD requirements in the regulations.  Just that after 2023, ROTH is excluded from the calculation. I'm not sure if it is address if a participant can take from the ROTH source to satisfy RMD after 2023 but my guess is that distributions from ROTH will no longer satisfy RMD requirements after 2023.

Posted
16 hours ago, Lou S. said:

I'm not sure if it is address if a participant can take from the ROTH source to satisfy RMD after 2023 but my guess is that distributions from ROTH will no longer satisfy RMD requirements after 2023.

I must say I hadn't yet even considered this aspect. I don't know if there's a firm answer or not, but thank you for bringing this to my attention! 

Posted

Since the RMDs are intended to ensure that retirees eventually pay taxes on sheltered money, I doubt Roth distributions would satisfy the RMD requirements after 2023.

Posted

No need to speculate.  The IRS says starting in 2024 you no longer have to take RMDs from designated Roth accounts.

https://www.irs.gov/retirement-plans/retirement-plan-and-ira-required-minimum-distributions-faqs

"Designated Roth accounts in a 401(k) or 403(b) plan are subject to the RMD rules for 2022 and 2023. However, for 2024 and later years, RMDs are no longer required from designated Roth accounts. You must still take RMDs from designated Roth accounts for 2023, including those with a required beginning date of April 1, 2024."

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