RBD for a 401(k)

My client is 77 and works for a company in which he has no ownership. He is likely to retire next year. If he works for the company for no more than one day in 2020, doesn’t that mean that the RBD for his 401(k) would be 4/1/21?



If he is considered still active by the employer for even one day in 2020 and then retires, 2020 will be his first RMD distribution year and the RBD would be 4/1/2021. If an employee’s last day is 12/31, they are considered retired on 12/31 even though they worked a full day on 12/31. In that case, the RBD would be only 3 months away.

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