Did all inherited IRA accounts have the same 5 beneficiaries named? While the decedent’s year of death RMD can be normally be completed in any combination by the beneficiaries, there are restrictions if the beneficiaries differ.  The confusing rules in that case are linked in paragraph 5 below.
Your client is not responsible for RMD shortfalls for years prior to the year of death (Prior to 2022). Prior to 2022 the owner’s RMD can be taken subject to the aggregation rules, from any combination of their IRAs.
Your client’s 2023 beneficiary RMD is calculated using your client’s share of each inherited IRA on 12/31/2022. Once that total RMD is determined it can be taken from any combination of inherited IRA accounts from the same decedent. But client can get confused if they maintain inherited IRA accounts with more than one custodian.
The 2023 beneficiary RMD must be determined using the new 2022 single life tables even if the 10 year rule applies, and it is not clear whether your client is an eligible designated beneficiary or a 10 year rule beneficiary. Since the decedent passed after RBD, the new proposed Secure Act Regs will require 10 year rule beneficiaries to also take annual life expectancy RMDs in years 1-9. Since this will not apply to client until 2023 (Year 1), the proposal’s final provisions should be clear by then.
Multiple Beneficiaries and the Year of Death RMD | Morningstar

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