Beneficiary IRA

I am stumped.  All help is appreciated.

  • T-IRA owner, age 39, died in 2017.
  • Mom is the sole beneficiary – she has been taking RMDs annually until her death in 2022.
  • Successor beneficiaries are Mom’s 2 daughters. – Daughters are subject to the 10-year payout.

Questions:

Are the daughters (i.e. successor beneficiaries) RMDs waived for 2024?  Does the recent IRS RMD guidance waiving certain RMDs apply?

Whose life expectancy do the daughters use (mom or their sister) – I am unsure here because the original beneficiary (mom) is older than the account owner.

 

Thank you

 



Yes, the 2024 beneficiary RMDs are waived as these distributions fall under the second type of specified RMD in Notice 2024-35. For purposes of successor beneficiary RMDs, mother is treated as an eligible designated beneficiary that passed, thereby triggering the 10 year rule for the daughters.

Daughters were responsible for completing mother’s 2022 year of death RMD if she did not do so since mother was not subject to the 10 year rule and a 2022 stretch RMD was due for her.

But there is another question here regarding 2025 and beyond that has not been clarified for successor beneficiaries. The original owner passed prior to RBD, and once the waivers expire in 2025, it is not clear whether the daughters must continue the RMD schedule of mother, or not.

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