Most have heard by now that Congress and the President have enacted legislation that suspends RMDs for 2009. The new rules affect both IRAs and qualified plans.
We have had a number of questions about how the new rules affect those turning 70 1/2 in 2008 and 2009. The situation is not 100% clear for either case. We do expect the Service to issue regulations or other clarification soon.
After the clarification is issued, we expect that the rules will provide:
- those who turned 70 1/2 in 2008 will have to make their first RMD distribution by April 1, 2009, but will not have to take their second RMD distribution by December 31, 2009
- those who turn 70 1/2 in 2009 will not have to make their first RMD distribution by April 1, 2010, but will have to take their first RMD distribution by December 31, 2010