Inherited IRA and qualified plan

Client opened up an inherited IRA as beneficiary of his deceased brother’s IRA. Turns out he is also beneficiary of his brother’s thrift savings plan.

Can he roll over the TSP into the existing IRA or is it better to open a separate IRA for the TSP? Code sections or other rationale for either position would be appreciated.



While the background rulings for the inherited qualified plan (TSP) rollover are included in the following link,
http://benefitslink.com/IRS/notice2007-7.pdf

I am not aware of any IRS release or analysis of multiple vrs single accounts. Certainly, the transfer could be made into a single account when inherited from the same beneficiary, but before making that decision, it should be determined whether there is any technical reason why the RMD would differ based on the sources of the funds.

For example, if the transfer was not made by the end of the year following death, the inherited IRA would be subject to the RMD requirement of the TSP. If the 5 year rule applied, then by commingling the sources, you would have a mess that there is not even a formal remedy for, but possibly it would subject the entire IRA to the 5 year rule. A similar thing could occur if there were multiple IRA beneficiaries and separate accounts were not created in time to avoid the RMD being based on the oldest beneficiary. However, if the RMD will be the same, I don’t see any downside to having both sources go to the same inherited IRA.

Another thing to consider here is the possibility of a Roth transfer from the TSP if the TSP offers the non spouse transfer. Obviously, if the beneficiary qualifed for this, the IRA would be an inherited Roth vrs an inherited TIRA and therefore two accounts. The income limits to the Roth transfer apply until 2010, but it is possible that the beneficiary has not other chance to have a Roth other than “converting” from the TSP.
This is discussed in Notice 2008-30 under PPA Sec 824 following:

http://www.irs.gov/pub/irs-drop/n-08-30.pdf



Add new comment

Log in or register to post comments