When can an employees account be divided into separate accounts so that each separate account may separately satisfy section 401(a)(9) following the employees death?
Separate accounts with different beneficiaries can be established any time. The separate accounting must allocate all post-death investment gains and losses on a pro rata basis between the different accounts until the separate accounts are established. The required minimum distribution rules will be applied separately to each separate account for years subsequent to the calendar year that the separate accounts are established. The separate accounts must be established by the end of the year following the year of the employee’s death in order to permit the distribution period for a separate account to distinct beneficiaries to be determined without regard to the beneficiaries of the other separate accounts.
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