401k participant over 72 – RMD for year of death?

Client is age 75. Still working and participating in 401k. Not a 5%+ owner in the company.

Client dies in June of 2021, with his surviving spouse named as sole beneficiary.

Is an RMD due for 2021, based on 12/31/20 value, and to be taken no later than April 1 of 2022?



Since he was still working, he passed prior to his RBD. There is no 2021 RMD due, so the surviving spouse could do the spousal rollover of the entire balance if this is completed prior to year end. If the surviving spouse leaves the balance in the plan after year end 2021, there will be a beneficiary RMD due in 2022. If a rollover to her own IRA is done this year, whether she has a 2022 IRA RMD due depends on whether she is RMD age.

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