Before you roll overWhat a retirement account costs, and what it forbids

Can this year's RMD go into the IRA with the rest of my 401(k)?


Summary

No. The IRS RMD FAQ asks, "Can RMD amounts be rolled over into another tax-deferred account?" and answers in one word: "No." The regulations also decide which dollars are the RMD: in a year when one is required, money coming out of the plan counts toward the RMD first, so if you roll over your whole balance midyear, the first part of it is treated as the RMD and can't go into the IRA.

The regulation's own example

Treasury Regulation 1.402(c)-2, which governs distributions made on or after January 1, 2025, works through a case. The employee's RMD for the year is $5,000 and the employee receives $7,200 in total. In the regulation's words, "the first $5,000 distributed will be treated as the required minimum distribution and will not be an eligible rollover distribution, and the remaining $2,200 will be an eligible rollover distribution if it otherwise qualifies."

The ordering is what trips people up. You can't send the rollover first and plan to take the RMD in December. In an RMD year the RMD comes to you and only the rest can go to the IRA.

Is an RMD due from this plan this year?

Situation First RMD due
Traditional IRA April 1 of the year after you reach 73
401(k), you've retired April 1 after the later of the year you reach 73 or the year you retire
401(k), still working and not a 5% owner April 1 after the year you retire, if the plan allows the delay
401(k), 5% owner of the employer April 1 of the year after you reach 73, working or not

The plan's own terms can override the delay: "A retirement plan document may require you to begin receiving distributions after you reach age 73, even if you're still employed." And if you push the first RMD to April 1, you take two in that year. The IRS example: reach 73 in 2024, first RMD by April 1, 2025, second by December 31, 2025.

Age 73 is the current figure, not a permanent one. Under SECURE 2.0, as restated in the Treasury regulations published in the Federal Register on July 19, 2024, "in the case of an individual who attains age 74 after December 31, 2032, the applicable age is 75."

One plan at a time

Holding several old 401(k)s means several RMDs. "These required distribution rules apply individually to each qualified plan. You cannot satisfy the requirement for one plan by taking a distribution from another plan." IRAs work differently: you calculate each IRA's RMD but "can withdraw the total amount from one or more of the IRAs."

Designated Roth money in a 401(k) has had no lifetime RMDs for taxable years beginning after December 31, 2023. Taking too little from the rest of the account costs a 25% excise tax on the shortfall, or 10% if it's corrected within two years.

Sources

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