RMD after 70 ½ still working, retired, re-hired

Teacher turned 70 ½ on December 30, 2017.
She retired mid-year in 2017.
She is receiving a teacher pension from her school district.

In 2018, she was re-hired as a W-2 part time worker with the same school district.

I would think she does not have to take her 2017 403b RMD’s by April 1 of this year or going forward while she is still employed with the same school district.

The current 403b plan and the older plans that are related to the same school district allow the deferral of RMD’s while still working.

Am I correct?



Per IRS Reg 1.401(a)(9)-2, Q 2, the required beginning date is 4/1 of the year following the year the employee retired or reached 70.5, whichever is later. In this case 2017 was that year, which means that 2017 is the first RMD distribution year with 4/1/2018 being the RBD. Once RMDs begin for a particular plan, they never stop. She cannot “un retire” in order to stop RMDs. The only way she could avoid RMDs would be if the district took the position that she did not really retire in 2017 and remained an active employee on their books. However, that does not appear to be the case, as you used the term “re hired” to describe her return to work in 2018.

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