401k RMD for employee over age 70.5

Client has never taken an RMD from his 401k, even though he is 75, because he was still a full time employee. He officially retired the end of January 2018, Last 401k contribution posted the following week. Since he was an active employee and 401k participant during 2018, is a 2018 RMD required? Is there a rule on how much of the year you have to work to fall under the employee exemption to the RMD? Thanks.



Whether there are contributions or not, if you retire at any point in a year, an RMD is required for that year.

The plan should have notified him by now that an RMD is required for 2018. Unlike an IRA, a 401k plan should be automatically distributing the 2018 RMD no later than the required beginning date, in this case 4/1/2019. If client does not receive the 2018 RMD by year end, he will then have to take 2 RMDs in 2019, the 2018 RMD by 4/1 and the 2019 RMD by 12/31/2019. Since he only worked one month in 2018, he would likely benefit by taking the 2018 RMD before year end, and therefore would be taxed on 1 RMD each year. The plan should have notified him of these options by now.

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