RMD Requirements for annuities inside IRA’s

I inherited a client with an IRA that their only investment inside the IRA was a variable annuity valued at approx $100,000 on December 31, 2006. Client annuitized contract (lump sum goes away, monthly payments begin) in July of 2007. If you calculate RMD for 2007 using the December 31, 2006 value, the six monthly payments received (July – Dec) will not be enough to satisfy the RMD calculated using the December 31, 2006 value. How does the IRS view this and is their an RMD calculation going forward?



There is no RMD calculation in years following the year of annuitization. However, for 2007 in this case, it appears to me that the shortfall in the indicated RMD after considering the months of annuity payments should have been distributed prior to annuitizing. At least, that is what the attached paste from the 2002 RMD requirements seems to indicate. Perhaps the insurer should be asked to clarify according to their own interpretation. Somehow, I doubt if the IRS is on top of this situation:

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“(e) Annuity contracts. Instead of
satisfying this A–1, the minimum
distribution requirement may be
satisfied by the purchase of an annuity
contract from an insurance company in
accordance with A–4 of § 1.401(a)(9)-6T
with the employee’s entire individual
account. If such an annuity is purchased
after distributions are required to
commence (the required beginning date,
in the case of distributions commencing
before death, or the date determined
under A–3 of § 1.401(a)(9)-3, in the case
of distributions commencing after
death), payments under the annuity
contract purchased will satisfy section
401(a)(9) for distribution calendar years
after the calendar year of the purchase
if payments under the annuity contract
are made in accordance with
§ 1.401(a)(9)-6T. In such a case,
payments under the annuity contract
will be treated as distributions from the
individual account for purposes of
determining if the individual account
satisfies section 401(a)(9) for the
calendar year of the purchase. An
employee may also purchase an annuity
contract with a portion of the
employee’s account under the rules of
A–2(a)(3) of § 1.401(a)(9)-8.”



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