Can One IRA Beneficiary Take Mom's RMD? - Ed Slott and Company, LLC

Submitted by Kathleen Hartman on Thu, 2022-07-28 14:17

Client and her six siblings were all named beneficiaries on Mom’s IRA. Mom died in March 2022 (age 92) before taking her 2022 RMD. All beneficiaries have opened Inherited IRAs and now have their portion in their Inherited IRAs. One sibling plans to cash out his Inherited IRA and the beneficiaries believe this will satisfy the untaken RMD. Assuming his withdrawal is at least equal to Mom’s RMD, is that strategy a correct way to take the untaken RMD for 2022?

IRS Publication 590-B “Distributions from Individual Retirement Arrangements (IRAs)” says the following, but the more I read it, the less I understand it.

Separate accounts.
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 required minimum distribution. However, these separate accounts or shares won’t 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.

Many thanks for your advice! Kathleen H.

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Permalink Submitted by Alan - IRA critic on Thu, 2022-07-28 16:04

The short answer is that the year of death RMD can be satisfied in any combination by the beneficaries, so the beneficiary is correct. If each beneficiary received 1/7 of Mom’s IRA, even with the loss of value since 12/31/2021, the inherited IRA balance of the one beneficiary should be large enough to cover Mom’s 2022 RMD. In more simple terms, the beneficiary taking the lump sum distribution just needs to confirm to the others that the lump sum is greater than Mom’s RMD. The others can then forget about participating in the year of death RMD.
The paragraph you quoted above with respect to post death distributions does not apply to the year of death RMD of the IRA owner. It does apply to the beneficiary’s inherited IRA RMDs that begin after separate accounts are established. The following bullet point is copied from IRS Reg 1.401(a)(9)-5 QA 4. It states that the year of death must be taken by “a” beneficiary, which means any beneficiary.
“Thus, a minimum required distribution, determined as if the employee had lived throughout that year, is required for the year of the employee‘s death and that amount must be distributed to a beneficiary to the extent it has not already been distributed to the employee.”