Pushing first stretch RMD to 12/31
§401(a)(9)(B)(iii)(III) states that the first stretch RMD must come out no later than 1 year from the date of death of the employee.
But 590-B states that the first RMD can come out as late as 12/31 of the year after the date of death. Does this “float” until the end of the year come from a reg? Or is it provided for in §401(a)(9) itself and I am just not seeing it?
Please and thank you.
Permalink Submitted by Alan - IRA critic on Thu, 2021-06-17 02:06
590B is correct, the deadline is 12/31. In interpreting the tax code, the IRS in Reg 1.401(a)(9)-5, QA 1 (c) stated:
“(c) Time for distributions. The distribution required to be made on or before the employee‘s required beginning date shall be treated as the distribution required for the employee‘s first distribution calendar year (as defined in paragraph (b) of this A-1). The required minimum distribution for other distribution calendar years, including the required minimum distribution for the distribution calendar year in which the employee‘s required beginning date occurs, must be made on or before the end of that distribution calendar year.”