Answer

Under the RMD rule, the first amount distributed from a retirement account includes the account owner’s RMD. This includes direct rollovers from the retirement account. As such, the amount which was rolled over to the traditional IRA already includes her RMD amount. As a result, the traditional IRA now has an excess contribution which must be corrected by her tax filing deadline, including extensions, in order to avoid the 6% IRS penalty.

Leaving the RMD behind to take later is not an option.

The following example illustrates:

Example

§ 80 year old individual’s 401(k) account has a balance of $400,000 as of December 31 of last year
§ She is required to use the uniform table[1], which indicates a life expectancy of 18.7 (for RMDs in 2021 and beyond the updated uniform table should be used)
§ Her RMD for this year is $21,390
§ She rolled over $200,000 from the 401(k) to her traditional IRA on January 2 of this year
§ She did not take the RMD before completing the rollover

The result:

Because she did not take the RMD before the $200,000 was rolled over to the IRA, the RMD of $21,390 is included in the $200,000. This means that the RMD was already satisfied for the 401(k) when the rollover amount was distributed from the 401(k). However, the rollover of the RMD has created an ineligible rollover of $21,390 to the IRA. This ineligible rollover has in turn resulted in an excess contribution, which needs to be corrected by her tax filing due date for this year, plus extensions. If she files her tax return by the due date, she receives an automatic 6-month extension to correct the excess (that is until October 15 of next year for calendar year filers).

The correction of the excess must include any net income attributable (NIA) (defined here https://iradictionary.com/definitions/netincomeattributablenia ).

The RMD for the IRA is a separate issue and must be taken from the IRA by the deadline (December 31).

Question Answered by http://www.applebyconsultinginc.com/DeniseAppleby.php Denise Appleby- IRA Guru