Aggregation of RMDs between the traditional and Roth accounts in a qualified plan
Where in the tax code is aggregation of the RMD between the traditional an Roth accounts in a qualified retirement plan supported? Wouldn’t such aggregation violate the separate accounting requirement for designated Roth accounts (§ 402A(b)(2)(B))?
How does this square with 26 CFR § 1.402A-1 Q&A 13 which prohibits any transaction or accounting method from transferring value between another of the employee’s accounts in the plan and the employee’s designated Roth account? (I’m guessing that this rule was not updated to reflect that in-plan Roth rollovers are now permitted since IRRs would seem to violate this rule.) It seems that allowing aggregation of the RMD would allow one to effectively transfer value from the traditional account to the designated Roth account by avoiding taking the RMD for the designated Roth account from the designated Roth account.
Permalink Submitted by Alan - IRA critic on Fri, 2022-06-24 14:08
Permalink Submitted by David Mertz on Fri, 2022-06-24 15:42