RMD distributions versus rollovers
For purposes of satisfying RMDs, an account owner is allowed to aggregate RMDs across multiple retirement accounts. In other words, if a client has a total RMD of $10k, and has two IRAs, he/she can take all from IRA#1, all from IRA#2, or any combination in between.
However, when executing a rollover, amounts subject to RMD are not eligible for rollover. This typically means that prior to making the rollover, you have to satisfy your RMD.
Question: do the aggregation rules also apply in the case of a rollover? In other words, if I have satisfied my total RMD obligation by taking a withdrawal from IRA #1, can I roll over both IRA#1 and IRA#2, even though no RMD has been taken from IRA#2?
Thx
Permalink Submitted by Alan - IRA critic on Thu, 2024-11-07 15:53
Yes, you can.
Final Secure Act Regs make it clear that distributions from any IRA must first be applied to the total RMD for all IRAs. But once the total RMD has been completed under the IRA RMD aggregation rules, additional amounts can be distributed from any of the IRAs. These additional amounts are often conversions, therefore no conversion can be done until the total RMD for all IRAs has been completed.
That’s a change from the prior rules, which allowed someone with multiple IRAs to distribute the RMD for just one of them and then convert from that same IRA before the RMD for the others IRAs had been completed. Those days are now gone.