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New Member
posted May 31, 2019 6:06:30 PM

Retired 12/31/15; turned 70 1/29/2016. Rolled over 401K to IRA in Feb 2015. Do I have to take an RMD from this rollover as an "ineligible rollover amount" this year?

The 401K provider is Principal, the IRA is in Scottrade.  Principal sent a letter to Scottrade insisting a portion of the rollover be taken out this year, but I wish to defer it to early 2017, and I have found nothing in the IRS or Treasury rules to state that I cannot wait to take this RMD.  I don't want to pay penalties, but don't need the extra income this year.  Principal insists it cannot be deferred until 2017.

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1 Best answer
Level 15
May 31, 2019 6:06:39 PM

2016 is an RMD year for your 401(k).  A rollover from a 401(k) to an IRA involves a distribution from the 401(k).  The first amounts distributed from your 401(k) in an RMD year are deemed to be your RMD until your RMD has been satisfied.  Assuming that you meant to say that the distribution from the 401(k) that was rolled over to the IRA occurred in February 2016, not 2015, the portion of the amount moved to the IRA that was 401(k) RMD has already satisfied your RMD, is deemed to be a regular contribution to the IRA, not a rollover, and is now an excess contribution to the IRA and you must request a return of excess contribution of this amount.  Since the RMD has already been made, it cannot be deferred to 2017.

See CFR 1.402(c)-2 Q&A 7(a):  https://www.law.cornell.edu/cfr/text/26/1.402(c)-2

Some IRA custodians can be a bit uncooperative in helping you make the corrective distribution from the IRA under these circumstances.  They must calculate any earnings or loss attributable to the amount of the excess contribution, distribute the adjusted amount, and report the distribution as a returned contribution, not a regular distribution.

How you enter everything into 2016 TurboTax for reporting on your 2016 tax return depends on how the 401(k) administrator reports the distribution that was moved to the IRA and whether the rollover was a direct rollover or an indirect rollover.

6 Replies
Level 15
May 31, 2019 6:06:32 PM

Feb 2015, or Feb 2016?

Level 15
May 31, 2019 6:06:33 PM

I see that you are asking from TT desktop using Windows XP.  2016 will not run on XP.

Level 15
May 31, 2019 6:06:35 PM

It seems certain the distribution and rollover occurred in 2016, otherwise Principal would have had no reason to send the letter to Scottrade.

New Member
May 31, 2019 6:06:37 PM

Yes, Feb 2016.  Yes, I know about the 2016 push to make computers obsolete.  I have a win 10, too.

Level 15
May 31, 2019 6:06:39 PM

2016 is an RMD year for your 401(k).  A rollover from a 401(k) to an IRA involves a distribution from the 401(k).  The first amounts distributed from your 401(k) in an RMD year are deemed to be your RMD until your RMD has been satisfied.  Assuming that you meant to say that the distribution from the 401(k) that was rolled over to the IRA occurred in February 2016, not 2015, the portion of the amount moved to the IRA that was 401(k) RMD has already satisfied your RMD, is deemed to be a regular contribution to the IRA, not a rollover, and is now an excess contribution to the IRA and you must request a return of excess contribution of this amount.  Since the RMD has already been made, it cannot be deferred to 2017.

See CFR 1.402(c)-2 Q&A 7(a):  https://www.law.cornell.edu/cfr/text/26/1.402(c)-2

Some IRA custodians can be a bit uncooperative in helping you make the corrective distribution from the IRA under these circumstances.  They must calculate any earnings or loss attributable to the amount of the excess contribution, distribute the adjusted amount, and report the distribution as a returned contribution, not a regular distribution.

How you enter everything into 2016 TurboTax for reporting on your 2016 tax return depends on how the 401(k) administrator reports the distribution that was moved to the IRA and whether the rollover was a direct rollover or an indirect rollover.

New Member
May 31, 2019 6:06:40 PM

A very well defined answer that is understandable and completely answered my question.  Thank you.