Is an RMD required from 401k at previous firm?

Client is 74 years old. His law firm merged into another law firm on 1/1/2019. He will participate in the 401k at his new firm.

The 401k at his old firm required RMDs because he owned over 10% of the firm. The 401k at the new firm will not require him to take an RMD. He will roll his old firm 401k to the new firm 401k. Does he have to take an RMD from the old 401k before he rolls it to the new 401k?



Yes. A direct rollover to a different plan will produce a 1099R since a direct rollover is a distribution. The RMD for the former plan must be distributed and not included in the rollover to the new firm’s plan.

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