RMD Rule for In-Service Direct Rollover of Pension

I turned 72 in October 2022. In December 2022 I received an in-service full distribution of a defined-benefit pension. I was told by the pension plan administrator that I did not owe an RMD, and one was not taken out of the distribution. I am still working for the same employer. The distribution was in the form of a direct rollover. The check was made out to the IRA custodian and sent to me. I had 60 days to deposit it. I delivered the check to the IRA custodian in person, and it was deposited to an existing traditional IRA in early January 2023. Prior to this deposit, this IRA had a balance of only 11 cents. It is my only traditional IRA. My question is when is/was the first RMD due and based on which end-of-year balance and which account (IRA or pension)? When is the second RMD due and based on which end-of-year balance?



  • The applicable IRS Reg addressing such rollovers is 1.401(a)(9)-7, QA 2. Since the pension distribution was made in 2022, your IRA year end balance for 2022 must be increased by the amount of the pension distribution. You have no IRA RMD for 2022, and your first IRA RMD year is 2023. There was no pension RMD for 2022 either as the plan indicated.
  • Your 2023 IRA RMD based on age 73 and the increased IRA balance on 12/31/2022 will be due by 12/31/2023. Your second IRA RMD will be due by 12/31/2024 based on age 74 using the 12/31/2023 IRA balance.

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