IRA RMD multiple benes

I have heard different answers from different CPAs on this topic. This is an inherited IRA RMD question. The individual passed in 2016, and he had not taken his RMD yet for the year. Say his IRA account was $100k on 12/31/15. He has two daughters that are 50/50 beneficiaries. One wants to keep the inherited IRA. The other wants to receive cash. We split the IRA assets into two bene IRA accounts. At age 91, the RMD divisor is 10.8.

If we distribute 50% = $50k to daughter #2 by check from here bene IRA, does that cover the RMD for this year 2016? My understanding is that is OK. I know next year 2017 they would have to take any remaining RMD separately if they both had accounts.

I see a few sources that lead to different answers. Can you please reconcile them?
1) Slott forum posting “IRA RMD in year of owner’s death” in 2010 and 2011 by Alan Oniras (I see many good contributions from Alan) which says “They don’t require it to be distributed equally to each beneficiary.”
2) IRS pub 590b (2015 version) page 12 “A single IRA can be split into separate accounts or shares for each beneficiary. These separate accounts or shares can be established at any time, either before or after the owner’s required beginning date. Generally, these separate accounts or shares are combined for purposes of determining the minimum required distribution. However, these separate accounts or shares will not be combined for required minimum distribution purposes after the death of the IRA owner if the separate accounts or shares are established by the end of the year following the year of the IRA owner’s death.”

It seems like Alan says “yes” RMD is satisfied, but Pub 590 says “no.” Maybe IRS guidance changed in recent years? Maybe there is a separate PLR?

Thanks for your help.



Since the year of death RMD is the decedent’s RMD and not a beneficiary RMD, it does not have to be taken equally, so beneficiary 1 does not have to take an RMD for 2016. The Pub 590 paragraph refers to the calculation of beneficiary RMDs based on the age of the beneficiary, and these would be effective in 2017.

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