Is a re-employed annuitant “retired” for RMD purposes?

BACKGROUND: A 70-1/2-year-old federal government retiree has returned to federal employment as a re-employed annuitant. Her new service is potentially creditable under the retirement system she retired from (pending deposit), and she is not currently participating in the TSP.

QUESTION: Is she required to take her first RMD by April 1 of next year — or is she considered still employed? Again, she retired once, but is employed again with the potential for additional credit under the same retirement system.



The TSP is responsible for defining whether she is considered “retired” or not despite re employment. Once RMDs begin due to retirement, re employment will not stop them. In this case however, she was re employed PRIOR to her required beginning date so it is not clear whether she must take an RMD for 2016 or not. It is up to the TSP to determine that and notify her. Her current participation status in the plan is immaterial to the RMD question.



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