401(k) in-Service Withdrawal plus RMD

Happy Holidays!

Any help with the following fact pattern is appreciated:

FACTS:
401(k) participant, 72 (non-5% owner)took a full in-service withdrawal in 2013
12/31/2013 401k value = $0.00
401(k) participant is retirement 1/3/2014

Question(s):
Is the participant subject to a 2013 401(k) RMD?

I would think “no” as their retirement date is not until 2014. On the flip side it seems the participant found a strategy to avoid a 2013 401(k) RMD

Thank you



You are correct, the 2013 RMD has been avoided as long as the plan is not one of the few that require all employees to start RMDs at 70.5. If that were the case, they would likely have made it clear to him in the past. Of course, if the distribution was rolled over to an IRA, then the IRA balance on 12/31/2013 will trigger a 2014 IRA RMD.



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