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Required beginning date

Key takeaway

For a traditional IRA owner, the required beginning date is the deadline for starting required minimum distributions after reaching the applicable age.

A required minimum distribution is often called an RMD. Identify each account before asking your custodian or plan administrator to confirm its first distribution deadline.

IRA timing and workplace plan timing

A traditional IRA owner's required beginning date is April 1 of the calendar year following the calendar year in which the owner reaches the applicable age. Continued employment does not postpone it.

SEP and SIMPLE IRAs follow the IRA distribution rules even though they receive employer contributions.

An employer plan's required beginning date generally is April 1 of the calendar year following the later of the calendar year the employee reaches the applicable age or the calendar year the employee retires.

Retirement postponement does not apply to a 5 percent owner. For that employee, the deadline is April 1 of the calendar year following the calendar year of reaching the applicable age.

A plan may instead set April 1 of the calendar year following the calendar year of reaching the applicable age as the required beginning date for all employees, regardless of ownership status.

Ask your plan administrator to identify the plan's rule before relying on retirement postponement. For an IRA, ask the custodian to confirm your applicable age and first distribution deadline.

The first distribution and later distributions

The first distribution calendar year's RMD may be completed by April 1 of the following calendar year. Subsequent annual RMDs remain due by the end of their own calendar years, including the year containing the required beginning date.

Deferring the first RMD into the following calendar year therefore puts two annual RMD deadlines in that year.

Before choosing when to take the first distribution, ask your tax adviser to compare withdrawal schedules. Bring account statements and the provider's deadline confirmation.

Why the date matters after death

If an owner dies on or after the required beginning date, any unpaid lifetime RMD for the year of death must be distributed to the beneficiary or beneficiaries during that year.

An owner who dies before the required beginning date has no lifetime RMD for the year of death.

For an inherited IRA or defined contribution account, a designated beneficiary who is not an eligible designated beneficiary must empty the account by the end of the calendar year containing the tenth anniversary of the owner's death.

If that owner died on or after the required beginning date, that beneficiary must also take annual life expectancy distributions in the first nine years.

Conduit trust: A see through trust requiring all retirement plan distributions it receives to be paid directly to, or for the benefit of, specified trust beneficiaries.

Accumulation trust: Any see through trust that is not a conduit trust.

A perspective on uncertainty

Alongside the deadline discussion, consider what uncertainty means for your own planning conversations.

"we do not know the rate that these funds are going to be taxed that in the future. And that's, you know, that uncertainty has a cost to it, right?"

From an Investor Advantage talk hosted by Richard C. Wilson

Common questions

Does a Roth IRA have a required beginning date?

No lifetime RMDs are required from a Roth IRA while its owner is alive. After death, beneficiary RMD rules apply as though the owner died before the required beginning date.

What age sets the required beginning date?

Current commencement rules use age 73 or 75 depending on birth cohort, while earlier cohorts retain their earlier commencement rules.

Ask the account provider to confirm your cohort before using an age to calculate a deadline.

Can an extra IRA withdrawal cover a future RMD?

No. For a traditional IRA owner, withdrawing more than one year's RMD does not create credit against future years' RMDs.

Can I roll over my IRA RMD?

No. The amount required to be distributed from an IRA as an RMD for a particular year is not eligible for rollover treatment.

This restriction concerns the required amount, rather than every dollar withdrawn during that year.

Can the tax on a missed IRA RMD be waived?

You may request a waiver if the shortfall resulted from reasonable error and you have taken, or are taking, steps to remedy it.

Relief is not automatic. Attach an explanation and complete Form 5329 as its instructions direct.

Sources

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