NUA available after RMD started?

Client has a 401k and worked until 78 so didn’t take RMDs.  Finally started taking RMDs at 79 and has taken every year since.  He is now 83.  We didn’t start working with him until this year and noticed he has company stock with significant appreciation.  We discussed NUA strategy primarily because he expressed getting more out for his 401k for his kids.

We called the plan administrator who said because he has taken RMDs out since 79 he cannot do NUA.  Does taking RMDs nullify the ability to complete an NUA strategy?

If it does not, would part of an NUA distribution count toward an RMD?



Not eligible per other thread, but if this had been his first RMD year, the share distributions would have counted toward the RMD.

What if the RMDs were taken from the non-stock portion of the 401k?

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