Inherited IRA RMD Requirements
Client has 2 inherited IRAs from same decedent, one IRA was inherited directly from decedent, the second inherited from same decedent but IRA was a stretch IRA (inherited from somone else first). Can we withdraw total RMD as if multiple inherited/beneficiary IRA from same decedent (combining life-expectancy distributions).
Permalink Submitted by tomd37 on Wed, 2010-12-01 22:09
My first question would be from whom were the IRAs inherited (spouse or non-spouse)? I am fairly certain that both the IRAs will have to be handled separately and the RMDs will have to be calculated and taken separately from each IRA. In the case of the second IRA (inherited stretch IRA) the RMD will be based on the age of the recent decendant and his/her RMD factor will be assumed by the new owner. Not sure how to reply about the first IRA since you do not mention from whom it was inherited (e.g., spouse or non-spouse). If non-spouse then RMD will be required. If spouse, I believe RMD may not necessarily be required. More information about the decedent would help all who would offer a reply. Can you help us with more details please?
Tom D.
Permalink Submitted by Alan Spross on Wed, 2010-12-01 22:49
No, the RMDs cannot be aggregated because the IRA accounts were not inherited from the same ORIGINAL decedent. Where client was the successor beneficiary, that IRA was inherited from the first beneficiary who named the client as successor beneficiary, so the actual decedent the client inherited from was different for these two IRAs.
The IRS Reg (1.408-8) that addresses aggregation could well have been more specific, because it does not directly address the issue of successor beneficiaries, who in fact inherit directly from the designated beneficiary and only indirectly from the original decedent. Taken literally, the client inherited these IRAs directly from two different decedents, and therefore the RMDs cannot be aggregated.
While the RMD divisors will also differ, that issue is not material to the question of aggregation.