RMD Clarification questions – IRA and 401(k) -?

Submitted by David Kay on Wed, 2023-11-29 19:21

Hello Forum – I have a female (not married) client who has an Traditional IRA. Her date of birth is 7/24/1951 (72). Does she need to take an RMD prior to 12/31/2023 or can she wait til next year as long as she takes prior to 12/31/24? Lastly, this client is also gainfully employed and participates in her employer’s sponsored 401(k) plan. It is my understanding that so long as gainfully employer and contributing to a qualified plan that NO RMD’s are required from this asset until the client stops working…true? Thanks in advance for your counsel / advice!!! Greatly appreciate!!



Submitted by Alan - IRA critic on Wed, 2023-11-29 20:50

  • 2023 is her first RMD distribution year, but all or part of the 2023 RMD can be delayed until 4/1/2024, not 12/31/2024. But her 2024 RMD must also be distributed by the end of 2024.
  • As long as she is not a >5% owner of the 401k employer, the “still working exception” excuses her from 401k RMDs until the year she retires. 
  • If the 401k will accept an IRA rollover, she could roll the IRA into the 401k (except for any IRA basis). She would have to first distribute the current year IRA RMD before the rollover to the 401k, but after the rollover year the IRA funds in the 401k would also be exempt from RMDs until she retires.

Submitted by David Kay on Wed, 2023-11-29 23:33

Thank you Alan for the quick and thorough reply!! Much appreciated.

Submitted by Soman Chacko on Sun, 2023-12-03 15:05

Per the Secure Act 2.0, starting age for RMDs is now 73. So this person who is 72 in 2023 can wait till Dec 2024 to make her RMD. She could actually wait till April 2025, but then will have to make two RMDs that year

Submitted by Alan - IRA critic on Sun, 2023-12-03 20:10

I agree. First RMD distribution year is 2024 (those with DOBs in 1951-1959).

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