Permalink Submitted by Alan - IRA critic on Tue, 2023-09-26 18:39
Yes, but the annuity RMD will have to be determined using the prior year end value of the annuity and the IRS will eventually have to publish Regulations on how to do that since an annuitized account has no year end balance unless some imputed value is determined. That said, Sec 204 of Secure 2.0 indicates that until the IRS publishes these regulations, the taxpayer can attempt to determine the year end value using a good faith estimate. The insurance company may or may not be able to assist.
Permalink Submitted by Jaime Quinones on Tue, 2023-09-26 20:01
In the case of a QLAC that is now in the income phase. Do the income payments from that QLAC count towards satisfying the client’s aggregate RMD’s from their retirement accounts?
Permalink Submitted by Alan - IRA critic on Tue, 2023-09-26 21:43
I would think so, but as in the case above the insurance company will have to determine an imputed account value of the QLAC once payments commence. There would then be a total RMD for the QLAC and both the non QLAC IRAs and the QLAC distributions would be part of the total RMD. Perhaps the insurance company has some advance info on how this will work.
Permalink Submitted by Alan - IRA critic on Tue, 2023-09-26 18:39
Yes, but the annuity RMD will have to be determined using the prior year end value of the annuity and the IRS will eventually have to publish Regulations on how to do that since an annuitized account has no year end balance unless some imputed value is determined. That said, Sec 204 of Secure 2.0 indicates that until the IRS publishes these regulations, the taxpayer can attempt to determine the year end value using a good faith estimate. The insurance company may or may not be able to assist.
Permalink Submitted by Jaime Quinones on Tue, 2023-09-26 20:01
In the case of a QLAC that is now in the income phase. Do the income payments from that QLAC count towards satisfying the client’s aggregate RMD’s from their retirement accounts?
Permalink Submitted by Alan - IRA critic on Tue, 2023-09-26 21:43
I would think so, but as in the case above the insurance company will have to determine an imputed account value of the QLAC once payments commence. There would then be a total RMD for the QLAC and both the non QLAC IRAs and the QLAC distributions would be part of the total RMD. Perhaps the insurance company has some advance info on how this will work.