Inherited IRA – missed 2021 RMD
Helping a client with their inherited IRA. Client (now 58 y/o) inherited a traditional IRA and Roth IRA from their sister (2 years older than Client) in 2020 post-SECURE Act. As an eligible designated beneficiary, client can take RMDs over their lifetime from both types of IRAs. Client did not know this, and did not take a 2021 RMD and has not yet taken a 2022 RMD. I started assisting in 2022, and we are now calculating how much of a RMD they must take to satisfy both 2021 and 2022.
My question is which numbers we use on the Single Lifetime Table to calculate both years’ RMDs? Since the sister passed in 2020, I assume we use the 2021 single lifetime table. Since Client was 57 years old at the end of 2021, we divide 12/31/2020 balance by 27.9. Then to calculate the 2022 RMD, we divide 12/31/2021 balance by 26.9, simply subtracting the life expectancy by one each subsequent year? Since we are doing our calculation under the assumption that the first RMD should have been taken in 2021, we should be using the 2021 Single Lifetime Tables? I don’t think the 2022 Single Lifetime Table is used at all in this case. Getting conflicting feedback from our custodian. Any help would be appreciated. Thank you!
Permalink Submitted by Alan - IRA critic on Tue, 2022-11-22 23:35
27.9 is correct for 2021, but for 2022 and beyond the divisors must be reset to reflect the new 2022 RMD tables. 29.8 would have been the 2021 divisor with the new tables, subtract one and the 2022 divisor will be 28.8. That figure should then be reduced by 1.0 for each succeeding year. Client will have to file a 2021 5329 requesting the penalty waiver for being late with the 2021 RMD. These two distributions will be taxable in 2022 if distributed before year end. Note that the recent IRS Notice waiving certain missed 2021 and 2022 beneficiary RMDs does not apply to EDBs like client.