I'm almost 72. I have an IRA, and a 401(k) from my last employer. I took my first required minimum distribution (RMD) from the IRA in 2019. No 2020 RMD is required, due to COVID-19. I was laid off on Oct. 1, 2020, also due to COVID-19. I'll receive severance through July 2021. I know I must take a 2021 IRA RMD. What about the RMD from my 401(k)?
You must take it by Dec. 31, 2021. The severance pay you'll receive in 2021 is for past work, says Ed Slott, a Rockville Centre tax accountant. "Your job ended in 2020 and that's what triggers your first RMD from the 401(k)."
You had to take the first RMD from your individual retirement account by April 1 of the year after you turned 70½. But you could delay taking an RMD from the 401(k) while you were still employed. (The deadline for first RMDs is now age 72, but only for people born after June 30, 1949.)
Since this is your first RMD from the plan, your deadline would normally be April 1, 2021 — the year after your job ended. But technically, it's a 2020 RMD. And as you say, 2020 RMDs have been waived. The Internal Revenue Service has already stated that for people in your situation — those who delayed taking RMDs from their employer's retirement plan while still employed, but left their jobs in 2020 — the first RMD from the plan qualifies for the 2020 waiver, says Slott.
The deadline for your second RMD (but the first you'll take, thanks to the waiver) is Dec. 31, 2021.
The bottom line
You can postpone your first RMD until April 1 of the year after it's due. All subsequent RMDs must be taken by Dec. 31.
CORRECTION: An earlier version of this story misstated the date associated with the age for taking the first required minimum distribution; it is June 30, 1949.
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