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Life and Death Planning for Retirement Benefits
1.3 RMDs During Participant’s Life
The minimum distribution rules come in two flavors, “life” and “death.” This
¶ 1.3
and
¶ 1.4explain the “life” rules, the rules that apply during the participant’s life. For the post-death
rules see
¶ 1.5
– ¶ 1.8 .An individual (the
participant
) who owns a retirement plan account must start taking
annual “required minimum distributions” RMDs) at a certain point in his life. This general
statement does
not
apply to Roth IRAs, which are not subject to the lifetime distribution
requirement; see
¶ 5.2.02 (A). Accordingly, this
¶ 1.3
does not apply to Roth IRAs. Also, see
¶ 1.1.04regarding the 2009 one-year suspension of RMDs.
For when lifetime RMDs must start, see
¶ 1.4.Once commenced, annual RMDs continue
for the rest of the participant’s life; for this rule and its exceptions, see
¶ 1.2.01 ,#2. Although the
computation of
post-death RMD
s can be radically different depending who is the beneficiary of
the plan (see
¶ 1.5
),
lifetime
RMDs are computed the same way for most people. See
¶ 1.3.01for
the method most people use (and the list of people who do
not
use it).
1.3.01
Road Map: How to compute lifetime RMDs
Follow Steps 1–8 below to compute a participant’s “lifetime” RMD for a particular year
(the “Distribution Year”) for a qualified retirement plan (QRP) or 403(b) plan account or
traditional IRA. Reg.
§ 1.401(a)(9)-5 ,A-4(a). This calculation must be done separately for EACH
IRA or plan account the participant owns; see
¶ 1.3.04 .As a reminder, this method does
not
apply
to defined benefit plans or to the “annuitized” portion of any DC plan; see
¶ 1.1.05 .Step 1:
Determine whether a distribution is required
for this year. If the participant has
not yet reached his “first Distribution Year”
( ¶ 1.4.01 ), you’re done—no RMD is
required. For the first Distribution Year itself, see
¶ 1.4.07 .If the participant has
passed his RBD, a distribution is required. If a distribution is required for the year,
proceed to Steps 2–8.
Step 2:
Determine the prior year-end account balance
for this plan or IRA. Se
e ¶ 1.2.05 – ¶ 1.2.08 .Step 3:
Determine the participant’s age.
See
¶ 1.2.04 .Step 4:
Obtain the ADP (divisor)
from the Uniform Lifetime Table
( ¶ 1.2.03 )for the
participant’s age (Step 3), unless the sole beneficiary of the account is the
participant’s more-than-10-years-younger spouse (in which case see
¶ 1.3.03 for
where to find the divisor).
Step 5:
Compute the current Distribution Year’s RMD
by dividing the prior year-end
account balance (Step 2) by the ADP (Step 4).
Step 6:
If the current Distribution Year is 2009
, reduce the amount obtained in Step 5
to zero. See
¶ 1.1.04 .Step 7:
Add any missed RMDs from prior years
to the amount obtained in Steps 1–6.
See
¶ 1.9.02 .