Pre-2020 Beneficiary RMD Clarification

Submitted by Steven Stern on Wed, 2023-03-22 21:27

I thought i finally had all the rules down but now I am second guessing myself on a rather basic RMD question.

Male is 55. He inherited his father’s IRA in 2017. His father was past his RBD age. Inheritor has been taking annual RMD’s based on his life expectancy since he inherited the IRA according to the rules.

QUESTION: Can he continue taking annual RMD’s over his life expectancy or is he now subject to the 10-year rule even if he inherited the IRA before 2020?

No article that i’ve read that discusses the recent proposed guidance OR Secure ACT ever mentions “pre-2020” inherited IRA’s being different than post 2020 Inherited IRA’s and nowhere is this mentioned in IRS publications. Everything only mentioned pre RBD age or Post RBD age but nothing about inheriting before 2020.

Please help and thank you!!



Submitted by David Mertz on Wed, 2023-03-22 21:41

  • He is to continue taking life-expectancy RMDs.  The 10-year rule only applies to those beneficiaries inheriting after 2019.
  • The life expectancy tables changed for 2022 and beyond.  Using the new tables, if he has not already done so he’ll need to recalculate his single life expectancy factor based on his age in the year following the year his father died, reduced by 1 each subsequent year.

Submitted by Steven Stern on Thu, 2023-03-23 12:58

Thank you! Do you know if this is expressly stated in any IRS guidance or legislation anywhere?

Submitted by Alan - IRA critic on Thu, 2023-03-23 16:05

  • The following is copied from the Secure Act text. In short, the 10 year rule only applies if either the plan owner or the beneficiary passes after the Secure Act effective date. LE RMDs started prior to the effective date (generally 1/1/2020) just continue on until the beneficiary passes, and in some cases to the successor beneficiary if the successor falls under the 10 year rule.  This is not one of those Secure ACt provisions that has been questioned.
  • “(3) EFFECTIVE DATES.—(A) IN GENERAL.—Except as provided in this paragraph and paragraphs (4) and (5), the amendments made by this subsection shall apply to distributions with respect to employees who die after December 31, 2019.”

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