Aggregation of RMDs between the traditional and Roth accounts in a qualified plan

Where in the tax code is aggregation of the RMD between the traditional an Roth accounts in a qualified retirement plan supported? Wouldn’t such aggregation violate the separate accounting requirement for designated Roth accounts (§ 402A(b)(2)(B))?

How does this square with 26 CFR § 1.402A-1 Q&A 13 which prohibits any transaction or accounting method from transferring value between another of the employee’s accounts in the plan and the employee’s designated Roth account? (I’m guessing that this rule was not updated to reflect that in-plan Roth rollovers are now permitted since IRRs would seem to violate this rule.) It seems that allowing aggregation of the RMD would allow one to effectively transfer value from the traditional account to the designated Roth account by avoiding taking the RMD for the designated Roth account from the designated Roth account.



  • SInce 402A and applicable designated Roth Regs are silent on RMDs, the 401(a)(9) Regs would apply by default. IRS Reg 1.401(a)(9)-8, QA 2 (a)  (DC plans) seem to treat the designated Roth as just another separate account within the DC plan, and states that RMD aggregation rules apply to all such separate accounts in the plan.  Nonetheless, some plans do not recognize this interpretation and require the Roth to be treated as an entirely separate plan rather than a separate account.  I believe the TSP is one of those plans.
  • Of course, if the pre tax plan pays out the entire RMD, it front loads tax collection. If the Roth has significant gains and is not yet qualified, any RMD from the Roth would be partially taxable, and this could be avoided by drawing the entire RMD from the pre tax account until the Roth was qualified.
  • Rollover to a Roth IRA prior to RMD age should still be done to prevent the Roth 401k balance from creating a larger RMD regardless of which separate account pays it. 
  • 26 CFR § 1.401(a)(9)-8 – Special rules. | CFR | US Law | LII / Legal Information Institute (cornell.edu)


  • 26 CFR § 1.401(a)(9)-8 Q&A 2 does seem to allow aggregation between the traditional and Roth accounts.  Although that regulation was made final in the Federal Register on 4/17/2002 after Public Law 107–16 was enacted on 6/7/2001, that was well before § 402A became effective in 2006 so that regulation might not have taken into account  § 402A(b)92)(B) and was never updated.  It seems contradictory to the separate account rule in § 402A, and statutes trump regulations.  I haven’t found any IRS guidance specifically on point that would clarify this.
  • You make a good point about taking the aggregate RMD from only the traditional account resulting in front-loaded tax collection.  That factor may make the IRS not particularly concerned about whether aggregation is done or not.
  • If none of the RMD paid from the Roth account is taxable (which is likely), one could likely accomplish the essentially same result by completing the traditional and Roth RMDs without aggregating, then rolling over from the traditional account to a Roth IRA (or doing an IRR if the plan allows) an amount equal to the RMD that was paid from the designated Roth account.  That’s another reason that the IRS might not care.


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