DCquestioner
Dec 9 2008, 12:49 PM
A new one man plan grants past service. The owner and only participant is in his 80's. He is vested in his benefit. Plan is effective 1/1/2007, so on 1/1/2007 the participant has an accrued benefit.
Since he was already past 70 1/2 on the plan's effective date, is his RBD 12/31/2007? or is it still 4/1/2008?
Thanks!
Blinky the 3-eyed Fish
Dec 12 2008, 03:12 PM
The RBD is 12/31/07. However, benefit accruals during the year must be factored into the RMD not until the following year. Past service or not, there is no RMD for 2007. I know you may want to argue that benefit accruals as of 1/1/07 were accrued prior to the current year. I would argue differently though as you can't accrue a benefit prior to a plan's effective date.