Hello,

I have the following scenario that I wanted to run by you:

In 2017, husband died at age 87. Wife was sole bene and did not treat assets as her own; she put into inherited spousal IRA (no idea why).

She would have had an RMD from her spousal inherited IRA based on her own single life expectancy, re-determined annually. She passed away in 2018 and left assets to her daughter. I am unsure how to calculate the daughter’s RMDs as the second inheritor moving forward:

1. Would we use the Mom’s schedule as a spouse bene and re-determine her age each year and use the corresponding factor on the single life table? So if Mom was 89 this year, had she not died, factor is 6.1.

2. Does it make a difference that Mom died before needing to take her first RMD as a beneficiary? Would that benefit the daughter’s RMD calculation method and allow daughter to be treated as the beneficiary of Dad’s original account?

3. Or would we use Mom’s age in year of death and reduce by 1? I found this guidance, but not sure if its applicable here.

§1.401(a)(9)-5 Required minimum distributions from defined contribution plans.

Q-5. For required minimum distributions after an employee’s death, what is the applicable distribution period?

A-5.
(c) Life expectancy–

(2) Spouse designated beneficiary. If the surviving spouse of the employee is the employee’s sole beneficiary, the applicable distribution period is measured by the surviving spouse’s life expectancy using the surviving spouse’s birthday for each distribution calendar year after the calendar year of the employee’s death up through the calendar year of the spouse’s death.

For calendar years after the calendar year of the spouse’s death, the applicable distribution period is the life expectancy of the spouse using the age of the spouse as of the spouse’s birthday in the calendar year of the spouse’s death, reduced by one for each calendar year that has elapsed after the calendar year of the spouse’s death.

Any help would be greatly appreciated. Thank you.