70 1/2 RMD this year

It is my understanding that a person who turns 70 1/2 in 2009 must still take their 1st RMD by april of 2010. They then must take their 2nd RMD by 12/31 of 2010. So essentially, for people who have to start taking their first RMD this year, the waiver of RMD’s for 2009 does not apply.

Can someone confirm this for me.



That is not correct. It is easier to keep this straight if you think only in terms of the distribution year, not the distribution date itself. The 2009 distribution year RMDs are the only ones waived. Therefore, anyone reaching 70.5 this year has a 2009 distribution year requirement, and it is totally waived, not just deferred to 2010. Someone turning 70.5 this year does not need to take their first distribution until 12/31/2010, and that will be their 2010 RMD.

Conversely, if you turned 70.5 in 2008, even though your first RMD could have been deferred until 4/1/2009, it is still a 2008 distribution year RMD and therefore is NOT waived. It must be taken out no later than 4/1/2009.

Anyone having delinquent RMDs as of 12/31/08 should take them out in 2009 ASAP to improve chances of any excess accumulation penalty charges being excused for reasonable cause.



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