RMD Requirement For Year of Turning 70.5
I have a client who turns 70 1/2 this year (Turned 70 on January 12th, 2017) and is still an active employee. In March of this year, he rolled a portion of his 401k to an IRA and left the other portion in the 401k plan. Since the rollover to the IRA happened during the year of turning 70 1/2 should the 401k provider have withheld the RMD for 2017?
Permalink Submitted by Alan - IRA critic on Fri, 2017-08-11 16:50
Unless client is a 5% owner, there is no 401k RMD for 2017 unless client retires before year end. If client does retire before year end the March rollover is applied against the RMD for the 401k, and must be reported as a taxable distribution. The RMD amount will allocated earnings will then have to be distributed from the IRA as an excess contribution because the RMD amount was not eligible for rollover. If client had indicated formal plans to retire this year, then the plan should have outlined his options with respect to the RMD and the rollover. However, just the possibility of retirement would not affect an in service rollover. Again, if client has not retired as of 12/31/2017, there is no RMD for the 401k plan unless client is a 5% owner. Note that there are a very few plans that require ALL employees to start RMDs at 70.5, but this is a relatively rare exception.