RMD RULES AND THE SEPARATION FROM SERVICE EXCEPTION: TODAY’S SLOTT REPORT MAILBAG
By Ian Berger, JD
IRA Analyst
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Question:
I turn 70 ½ this year and my last day of work was September 30, 2019. Am I required to take an RMD from my work profit sharing 401(k) plan by April of 2020 and, if so, is the RMD calculated on the 12/31/18 account balance? My employer will roll my profit sharing 401(k) into my IRA on January 2, 2020.
Thank you for your help.
Answer:
This is a question that trips up a lot of people.
Since you are separating from service and turning age 70 ½ in 2019, you must take your first RMD for 2019. That RMD is based on your December 31, 2018 account balance. Since this is your first RMD, it can normally be delayed until April 1, 2020. Even if you delay your first RMD until 2020, you also must take an RMD for 2020 based on your December 31, 2019 balance. So, if you delay your 2019 RMD until 2020, you will have two taxable RMDs to take during calendar year 2020.
You mentioned that a rollover will occur in early January 2020. Be careful! As mentioned, you could normally delay the 2019 RMD until April 1, 2020, and the 2020 RMD would normally not be due until December 31, 2020. However, since you are rolling over your 401(k) funds in January 2020, you must first take both your 2019 RMD (if you haven’t already taken it) and your 2020 RMD before doing the rollover. RMDs are not eligible to be rolled over. Once you take the RMDs, you can roll over the remaining funds tax-free.
Question:
Hello,
My husband and I are hearing conflicting stories about whether he will be able to withdraw from his retirement plan without penalty when he turns 50 this August. After reading your article we are still confused. He retired after 30 years of service at age 48.
Can you please clarify this for us?
Thank you for your time!
Dana
Answer:
Hi Dana,
Unfortunately, if no other exception applies, your husband would be subject to the 10% early distribution penalty if he takes a distribution at age 50.
There is an exception to the 10% penalty for employees who receive a company plan distribution after separating from service in the year they turn age 55 or later. For local, state and federal public safety workers, the exception applies for employees who receive a company plan distribution after separating from service in the year they turn age 50 or later.
If your husband was a governmental public safety employee, the age 50 exception doesn’t apply because he retired before the year he turned age 50. If that is the case, it won’t matter if he waits until age 50 to take his distribution.
If your husband wasn’t a governmental public safety employee, the age 55 exception doesn’t apply either since he retired before the year he turned age 55.