Client in his late 70’s retired from his job last year. Money stayed in the 401(k) until this year. Client has existing dollars in an IRA Annuity with a living benefits rider. In January, the client wanted to roll his 401(k) into a self directed IRA. Client took the RMD from the 401(k) and then did a direct rollover to the self directed IRA. Client would like to take the RMD for the IRA annuity from the new self directed IRA. Is that allowed? Can you take a distribution from an IRA that had no value on 12/31 of the prior year and have it count as the RMD for an IRA that did have a value on 12/31 of the prior year?

Thanks for the help,
RP