401(k) to IRA rollover and RMD requirement

A still working 74 year old rolls over a portion of his 401(k) to an IRA in 2022. Since the IRA balance was $0 on 12-31-2021, does he have to take a RMD from the IRA in 2022?



No, there is no IRA RMD for 2022 if the prior year end balance was 0. Note that he must still be employed on 1/1/2023 or 2022 will become a 401k RMD distribution year, and the RMD portion of the amount rolled over would not be rollover eligible. This would cause an excess IRA contribution.

Thank you for your usual expert assistance. That’s what keeps me paying my annual subcription. 

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