Facts:

Client’s brother died in 2022. The brother named client the 100% primary beneficiary of both his Traditional IRA and Roth IRA. Client has already rolled over the proceeds of deceased brother’s IRA and Roth IRA to a newly established Inherited Traditional IRA and Inherited Roth IRA.

The brother was 65 when he died. Client is 70.

Based on these facts, it appears the client is an eligible designated beneficiary, and because of that, it appears the client must take RMD’s on the basis of their own life expectancy over their lifetime.

Questions:

1. Is it correct that, being an eligible designated beneficiary, the client is NOT also subjected to the 10 Year Rule?

2. Because the deceased brother did not have a 2022 RMD obligation (since he had not yet reached his Required Beginning Date), is it correct that the client does NOT need to take an RMD in 2022 from his Inherited Traditional IRA and Inherited Roth IRA, and that the first RMDs won’t be required until 2023? Or is the client required to take RMDs in 2022?

Thank you.