Timing of RMD
If RMD must be taken in “the year” that owner becomes 70 1/2 , does that mean that a withdrawal during the calendar year the owner will become 70 1/2 qualifies as part or all of RMD even if it is made before the actual date the owner turns 70 1/2 ?
Permalink Submitted by Alan Spross on Thu, 2009-12-24 01:07
Yes, the first distribution taken in the calendar year IRA owner turns 70.5 is deemed to apply to the RMD for that year. That does not mean that any distribution MUST be taken that year since the first RMD required beginning date (RBD) is 4/1 of the year following the year IRA owner turns 70.5. But if any distribution is taken, it is applied to the RMD for the 70.5 year.
Obviously, for 2009 there are exceptions due to the RMD waiver. In 2009, the first distribution for someone 70.5 is NOT considered to be an RMD because the RMD has been waived. Therefore, that distribution can be rolled over within 60 days or the extended period that ended on 11/30 for those who were not able to stop the RMD distribution or did not know about the waiver.
Permalink Submitted by John Hemphill on Thu, 2009-12-24 16:00
Thanks for the reply. That seemed to make sense but i could not find it clearly stated in IRS publication. Do you have a ready reference to an IRS bulletin that corroborates our conclusion?