Roth 401k and Roth IRA relationship re RMD

I realize IRAs and 401k operate according to some different rules, but I seek some clarity: I opened my first Roth IRA in April 2010. It continues to exist. No distributions have been taken from it. I had been contributing to a Traditional 401k at my job until 2013 when I changed my contributions to a Roth 401k at the same employer. Therefore my 401k had both Traditional and Roth elements when I retired in late January 2016. I elected to take the first RMD in 2016. The 401k implementer is Principal. Principal insisted on taking a portion of the RMD from the Roth element and the balance from the Traditional portion. I presume this was on a proportional basis according to the relative Roth and Traditional dollar balances, but I am not certain. I received a 1099-R from Principal that indicated a sum that showed in Box 2a a taxable amount and the gross distribution in Box 1.

Is this taxable amount because of from the employer’s match after I switched to contributing to the Roth 401k? Or, is it that for some reason the Roth distribution is taxable? I noted above that the Roth 401k had not been opened for five years although the Roth IRA elsewhere was first opened in 2010, more than five years before. If the Roth part of the RMD was taxable because I had not had the Roth 401k open for five years, is this not double taxation since my contributions to the Roth 401k ware after tax dollars? Does the fact that the Roth IRA was opened more than five years before the RMD count as the five-year requirement to avoid taxation on a Roth IRA that was younger than five years? Or does the Roth IRA’s five year period not get me off the hook for the five-year requirement for the Roth 401k portion of the RMD.

Is my situation clear enough for response? Thank you. Douglas.



  • Douglas, you should receive 2 1099R forms for the 401k distributions, one coded 7 for the traditional 401k distribution and another coded B for the Roth 401k distribution. The tax code allows you to aggregate your RMD between the traditional and Roth meaning that you could elect to take the entire RMD from one portion, but the plan provisions may not allow anything but pro rate. So at this point it is not clear whether your total RMD was taken in proportion to the balance or if it all came from the pre tax portion. You might have to wait until you get the second 1099R, but now you could still verify if the 1099R you have reports the total RMD you took out in Box 1 or not. Taxation of course will differ according to which portion of the plan made the distribution.
  • There would not be double taxation. Any distribution from your Roth 401k is not qualified, but would include a pro rated amount of earnings. For example, if your Roth 401k balance was 80% contributions and 20% earnings, then 80% would be non taxable and 20% taxable.
  • If you roll over the Roth 401k into your Roth IRA, not only will your Roth RMDs end, but the entire amount that you would withdraw would be tax free because the Roth 401k would become fully qualified when it is rolled into a qualified Roth IRA. Your Roth IRA is already qualified. However, you still cannot avoid a Roth 401k RMD for 2017 because you still had a Roth 401k balance on 1/1/2017.
  • For 2017 you might check if you can take the full RMD from the pre tax portion of the plan which will be taxed, and not from the Roth 401k because all the Roth 401k money will avoid taxes after it is moved to your Roth IRA. This would increase your taxes for 2017 but reduce them a little for every year thereafter since your pre tax account would be lower and your Roth IRA would be totally tax free.
  • If some of this is not clear, please advise. 


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