RMD still-working exception
I have a client who turned 72 this year and may want to take advantage of the still-working exception. He retired from company A to work for company B, which is a contractor for company A. His plan is still under company A and they still consider him an active employee-even after 6 months of retirement. The client projects that his W-2 will be reported under company B which appears to be a threat/conflict to using the exception. Is compliance on the exception determined solely by plan reporting or will the W2 need to match the EIN of the plan sponsor?
Permalink Submitted by Alan - IRA critic on Tue, 2022-12-06 16:17
It depends on the details and extent of common ownership of the 2 companies and their business entity type and any changes of business entity. If they are totally unrelated, then there needs to be a separate plan for each and client will have a 2022 RMD with an RBD of 4/1/2023. Otherwise, much more detail is required. What is Company A’s position on this? They are responsible for complying with RMD requirements as well as many other tax compliance issues.