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How Recent Changes to RMD Rules Apply to Puerto Rico Participants in Dual-Qualified Plans
Ogletree Deakins 
[Guidance Overview] July 16, 2020 "[B]ecause Puerto Rico participants are generally subject to the payment of Puerto Rico income tax on the distribution of retirement benefits and RMDs are ineligible for tax-free rollovers under the Puerto Rico Internal Revenue Code, for local tax purposes a purported rollover of RMDs would be a taxable distribution. When implementing the recent [IRS] guidance allowing for rollovers of 2020 RMDs, sponsors and administrators of dual-qualified plans may want to consider informing Puerto Rico participants that in their cases such rollovers may have adverse tax consequences." |
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