A new plan is set up for an employer who has several participants who are 5% owners and who are over age 70 and 1/2. Some are well into their 80s and are close to 90 -really!!. (We should all be so healthy!!!) I am assuming that a contribution can be made on behalf of these senior-senior citizens, but how does MRDs work for them. Are they given the grace period to the following 4/1 for purposes of receiving their first MRD and then double up in such year or must they take their first MRD by 12/31/03, the second by 12/31/04, etc....

In the first year there will be no minimum distribution required because on the valuation date the assets will be zero. Unless this is a DB plan that grants past service, then you would have a distribution by 12/31/03.

If this is a new plan, and NRA is defined as the later of 65 and 5th anniversary of participation, then there may be no vested benefit yet.