fb-rmd-0033
{
"person": "Retired employee who began voluntary installment distributions from his profit-sharing plan at age 71",
"facts": "His required beginning date, under 1.401(a)(9)-2(b)(1), falls on April 1 of the year after he attains his applicable age of 73. He dies in February of that applicable-age year — after two years of voluntary installments, but before his required beginning date. The plan had even distributed, a month before his death, an amount equal to what would have been his first-year required minimum distribution.",
"question_context": "Which set of after-death rules governs distributions to his beneficiary: the rules for death BEFORE distributions have begun, or the rules for death after."
}For section 401(a)(9) purposes, did this employee die before or after his distributions are treated as having begun? Answer with exactly one option id.
died-before-distributions-began— Before — distributions are not treated as having begun until the required beginning date, regardless of earlier paymentsdied-after-distributions-began— After — two years of installments means distributions had begundepends-on-first-year-rmd— After, because the plan had already paid the first-year RMD amount
died-before-distributions-began
Under 1.401(a)(9)-2(a)(3)(ii), distributions are not treated as having begun in accordance with section 401(a)(9)(A)(ii) until the required beginning date, even if the employee received payments earlier by election or plan terms — and the regulation says this holds without regard to whether the plan had distributed the first-year minimum before death. Dying before his April 1 required beginning date, he is treated as dying before distributions began, and the before-RBD after-death rules of 1.401(a)(9)-3 govern.
Selects died-before-distributions-began; both distractors are the trap the regulation's own example refutes.
“distributions to the employee are not treated as having begun in accordance with section 401(a)(9)(A)(ii) until the employee's required beginning date”
“This is the case without regard to whether, before A's death, the plan distributed the minimum distribution for the A's first distribution calendar year”
Each quoted passage is exact-matched, after typographic normalization, against the corpus text fetched from the issuing authority (hashes in the corpus manifest). An item whose quote stops matching fails the build.
“Thus, even if payments have been made before the employee's required beginning date, the rules of § 1.401(a)(9)-3 will apply if the employee dies before that date.” — cfr-1-401a9-2
The employee died before his stipulated required beginning date. The cited rule expressly provides that earlier payments do not change the result: § 1.401(a)(9)-3 applies when death occurs before that date. The source also specifically says the result is unchanged if the plan already distributed the minimum for the first distribution calendar year. Therefore, the key correctly selects died-before-distributions-began.
“Thus, even if payments have been made before the employee's required beginning date, the rules of § 1.401(a)(9)-3 will apply if the employee dies before that date.” — cfr-1-401a9-2
The stipulated facts match § 1.401(a)(9)-2(a)(3)(ii) and its profit-sharing installment example: voluntary payments beginning at 71, RBD of April 1 of the year after attaining applicable age 73, death before that RBD (including after a first-year minimum was paid). The regulation treats distributions as not having begun until the RBD regardless of earlier payments, so the key value died-before-distributions-began and its derivation are right.
v1; no errata. Demonstrate a key error and the correction is published here, credited — challenge policy.