Post SECURE, post RBD, non-spouse, non-EDB inherited traditional IRA RMD

[secondcor521]

That's a lot of TLAs.

I'm aware that there are proposed IRS regulations requiring RMDs for non-spouse, non-EDB beneficiaries of traditional IRAs which are post SECURE 2.0, post RBD during the 10 year period.

For a 54 year old beneficiary, I'm assuming:

1. They'd use the divisor table that has all ages. They would not use the one that starts at age 72 and would not use the 2D one for spouses not younger than 10 years.

2. They'd use their age as of the year of death of the original owner, and their portion of the year end balance in the year of death to get their initial divisor from the table in (1) to get their first year RMD amount.

4. They'd then subtract one from the initial divisor for the subsequent nine years of the 10 year period.

I'd appreciate confirmation or correction of my assumptions.

Please and thank you.

[secondcor521]

If those questions are too specific or arcane, as an alternative I would appreciate a pointer to the proposed IRS regulations so I can parse those for my particular situation.

[Alan S.]

That's a lot of TLAs.

I'm aware that there are proposed IRS regulations requiring RMDs for non-spouse, non-EDB beneficiaries of traditional IRAs which are post SECURE 2.0, post RBD during the 10 year period.

For a 54 year old beneficiary, I'm assuming:

1. They'd use the divisor table that has all ages. They would not use the one that starts at age 72 and would not use the 2D one for spouses not younger than 10 years.

2. They'd use their age as of the year of death of the original owner, and their portion of the year end balance in the year of death to get their initial divisor from the table in (1) to get their first year RMD amount.

4. They'd then subtract one from the initial divisor for the subsequent nine years of the 10 year period.

I'd appreciate confirmation or correction of my assumptions.

Please and thank you.

Yes, the single life table will apply using the divisor for the age of the beneficiary in the year FOLLOWING the year of death. That divisor is then reduced by 1.0 for each successive year, so the table only needs to be accessed once.

Their portion of the year end balance at the end of the year of death will be used with the first divisor.

The beneficiaries are also jointly responsible for completing the year of death RMD of the decedent if they did not. This does not have to be done pro rata.

It's possible that the IRS could change their mind again about the RMDs in years 1-9 of the 10 year rule, but every indication suggests they will not. These annual RMDs have been waived through 2023 but are expected to be required starting in 2024.

[secondcor521]

Alan, thanks for the response and confirmation/correction. I note and understand the "FOLLOWING" correction regarding the proper age to use, and it makes sense. Thank you!

Also understand about completing the year of death RMD, thanks.