Revised IRS RMD Table?

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Strider
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Revised IRS RMD Table?

Post by Strider » Fri Dec 27, 2019 11:45 am

Now that The Secure Act has been signed into law, the age for taking one's first RMD will now be 72 rather than 70 1/2 (true for those who have not turned 70 1/2 as of 12-31-2019). The reason cited for this change is the longer life expectancy of Americans.

Does the new law require the IRS to revise its RMD Table for IRAs (changing the various divisors) to take account of this longer life expectancy?

Strider

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Stinky
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Re: Revised IRS RMD Table?

Post by Stinky » Fri Dec 27, 2019 11:47 am

Strider wrote:
Fri Dec 27, 2019 11:45 am
Now that The Secure Act has been signed into law, the age for taking one's first RMD will now be 72 rather than 70 1/2 (true for those who have not turned 70 1/2 as of 12-31-2019). The reason cited for this change is the longer life expectancy of Americans.

Does the new law require the IRS to revise its RMD Table for IRAs (changing the various divisors) to take account of this longer life expectancy?

Strider
Separately from the new law, a new table has recently been proposed. You can find reference to it in internet searches.

Since the new table is not yet adopted, discussion of it is not permitted on the Forum.
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Strider
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Re: Revised IRS RMD Table?

Post by Strider » Fri Dec 27, 2019 11:53 am

OP here.

My question was whether The Secure Act requires the IRS to issue a revised table. I was asking about the specific language of a bill already signed into law. I did not ask anyone to post such a hypothetical table.

Strider

rkhusky
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Re: Revised IRS RMD Table?

Post by rkhusky » Fri Dec 27, 2019 12:07 pm

The proposed table was published in November. It is out for comment: https://s3.amazonaws.com/public-inspect ... -24065.pdf. So, if you have any comments, send them to the IRS.

The publication was already noted by bsteiner on Nov 7: viewtopic.php?f=2&t=294455 As usual, Bogleheads are on top of things. And as noted by moderator Misenplace, it is permissible to discuss the tables, since they are published for public comment.

Also see here:viewtopic.php?f=10&t=298153
Last edited by rkhusky on Fri Dec 27, 2019 12:13 pm, edited 2 times in total.

Geologist
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Re: Revised IRS RMD Table?

Post by Geologist » Fri Dec 27, 2019 12:11 pm

Strider wrote:
Fri Dec 27, 2019 11:53 am
OP here.

My question was whether The Secure Act requires the IRS to issue a revised table. I was asking about the specific language of a bill already signed into law. I did not ask anyone to post such a hypothetical table.

Strider
The Secure Act does not require the IRS to issue a revised table. However, as other posters have noted, one was proposed independent of the bill (and it is not hypothetical). There are other threads on this board that discuss it.

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Re: Revised IRS RMD Table?

Post by LadyGeek » Fri Dec 27, 2019 12:47 pm

Here's a brief overview on the difference between legislation and regulations. From Re: Political comments and proposed tax plan remain off-topic:
LadyGeek wrote:
Fri Nov 03, 2017 8:46 pm
...Legislation is US law. After Congressional bills become laws, Federal agencies are responsible for putting those laws into action through regulations. This process may include the following steps:*
  1. An agency initiates a rulemaking activity, and adds an entry to its Regulatory Agenda
  2. A Proposed Rule or other document is published to Regulations.gov
  3. The public is given the opportunity to comment on this rule for a specified timeframe
  4. Final Rules can be accessed on Regulations.gov
Therefore, "regulations" are rules imposed by the departments and agencies of the Federal Government. The Internal Revenue Service is a federal agency under the U.S. Treasury Department (also a Federal agency).**

We permit discussions regarding "proposed regulation" when they are published for public comment...

* Source: Frequently Asked Questions, regulations.gov.
** Source: Internal Revenue Service , federalregister.gov.
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Stinky
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Re: Revised IRS RMD Table?

Post by Stinky » Fri Dec 27, 2019 1:04 pm

LadyGeek wrote:
Fri Dec 27, 2019 12:47 pm
Here's a brief overview on the difference between legislation and regulations. From Re: Political comments and proposed tax plan remain off-topic:
LadyGeek wrote:
Fri Nov 03, 2017 8:46 pm
...Legislation is US law. After Congressional bills become laws, Federal agencies are responsible for putting those laws into action through regulations. This process may include the following steps:*
  1. An agency initiates a rulemaking activity, and adds an entry to its Regulatory Agenda
  2. A Proposed Rule or other document is published to Regulations.gov
  3. The public is given the opportunity to comment on this rule for a specified timeframe
  4. Final Rules can be accessed on Regulations.gov
Therefore, "regulations" are rules imposed by the departments and agencies of the Federal Government. The Internal Revenue Service is a federal agency under the U.S. Treasury Department (also a Federal agency).**

We permit discussions regarding "proposed regulation" when they are published for public comment...

* Source: Frequently Asked Questions, regulations.gov.
** Source: Internal Revenue Service , federalregister.gov.
Thank you for the reminder as to what’s permissible to discuss and what’s not.
It's a GREAT day to be alive - Travis Tritt

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Re: Revised IRS RMD Table?

Post by Alan S. » Mon Jan 13, 2020 1:46 pm

The ARA is now asking the IRS to provide Regulations regarding implementation of the new RMD tables (effective 1/1/2021) by 7/1/2020, ie provide 6 months lead time.

https://www.asppa.org/sites/asppa.org/f ... tables.pdf

They also want the new Regs required by the Secure Act passage to be completed prior to the Regs for the proposed new tables. Note that Congress passed the Secure Act just 12 days before it was effective.

And comments from Spark Institute: https://www.sparkinstitute.org/wp-conte ... .7.20-.pdf

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