Still Working Exception and Rollover from Qualified Plan to IRA

I am doing some tax planning for a person who is 75. This person did an in-service distribution of about $400K from TIAA (her current active retirement plan) in mid year 2022 to an IRA. I am trying to determine if she should have taken an RMD in 2022. I know that she didn’t have a 12/31/21 IRA balance, but based on the IRS FAQs on this subject it is making me think that she should have had an RMD on the amount rolled over because the still working exception didn’t still apply on those funds. I know that she has an RMD for 2023 on that amount, the impact on 2022 is my only question. Any thoughts or links that you could provide would be appreciated.



There was no IRA RMD for 2022 because there was no IRA balance on 12/31/2021. I assume that this person was still employed at the end of 2022 which eliminated an employer plan RMD for 2022. 

Yes, she is still currently employed today.  Thank you for the clarification!

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