We have a client with an existing 72(t) IRA. They also have a 401(k) they would like to rollover. Would it be considered a modification if we open a completely new IRA to roll the 401(k) into? The existing 72(t) IRA would not receive any funds form the rollover, so we are leaning towards it not being considered a modification.

What are your thoughts, and do we have any specific sources clarifying this?

Thank you!