If you missed a 2008 RMD for an employee that was due 4/1/09 and it is under $75 does it actually have to be made? Do they still expect me to file a VCP application if I am using this De Minimus rule? Obviously based on the amount, I would just pay the excise tax instead of filing VCP.

I would think this de minimus rule clearly relates to SCP situations but does it apply to situations where a VCP application is required?

Thanks

FWIW - I think you must make the RMD, but just under SCP - and pay the penalty tax.

I think you'd only use VCP if the facts and circumstances dictated that SCP was not available. And you could then request a waiver of the excise tax as part of the VCP filing.