I have a client who had both an IRA and a Solo 401k on 12/31/2018. In May 2019, they did a trustee to trustee transfer from one custodian to another to move the IRA in to the Solo 401k. However, have now realized that the IRA had its own RMD that cannot be met by taking a distribution from the Solo 401k (we think?), and would like to have the ability to process a QCD for part of the RMD which is allowable in an IRA but not the Solo 401k. Therefore, since we are still within the same calendar year, they are considering setting up a new IRA with the new custodian and doing another transfer (an internal transfer within the custodian) from the Solo 401k to a new IRA so that the RMD can be taken from an IRA and also some can be distributed via QCD. There are several moving parts here, but the question is does this runs afoul of any IRA or transfer rule? It seems that the transfer from Solo 401k to new IRA should be allowable since none of the transfers are done as a 90-day rollover, and the tax forms for the new IRA will show IRA distributions as required by the old IRA’s 12/31/2018 balance. Another question would also be: is there any requirement about how much should/can go back from Solo 401k to the new IRA, ie, does the exact amount that transferred from IRA to Solo 401k have to be what transfers back from Solo 401k to new IRA? Or can the client choose any amount that they desire? Thanks in advance…