Aggregate IRA values for a Beneficiary RMD?

We have a client who inherited two separate IRAs from the same IRA owner. Is the beneficiary able to aggregate the value of both IRAs, for RMD purposes, but only distribute from one?



Yes, in this situation the RMD can be aggregated. As usual, the individual RMD of each account should be figured and the total added up rather than just adding the balances and using a single divisor. There are some reason that a single divisor may not apply or all inherited IRA accounts, eg one of the IRAs may have multiple beneficiaries and the client may need to use the oldest beneficiary’s age for that one. Also, note that inherited IRAs under the 5 year rule cannot be included. Following copied from IRA Regs 1.408-8:

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Q–9. Is the required minimum distribution from one IRA of an owner permitted to be distributed from another IRA in order to satisfy section 401(a)(9)?

A–9. Yes, the required minimum distribution must be calculated separately for each IRA. The separately calculated amounts may then be totaled and the total distribution taken from any one or more of the individual’s IRAs under the rules set forth in this A–9. Generally, only amounts in IRAs that an individual holds as the IRA owner may be aggregated. However, amounts in IRAs that an individual holds as a beneficiary of the same decedent and which are being distributed under the life expectancy rule in section 401(a)(9)(B)(iii) or (iv) may be aggregated, but such amounts may not be aggregated with amounts held in IRAs that the individual holds as the IRA owner or as the beneficiary of another decedent. Distributions from section 403(b) contracts or accounts will not satisfy the distribution requirements from IRAs, nor will distributions from IRAs satisfy the distribution requirements from section 403(b) contracts or accounts. Distributions from Roth IRAs (defined in section 408A) will not satisfy the distribution requirements applicable to IRAs or section 403(b) accounts or contracts and distributions from IRAs or section 403(b) contracts or accounts will not satisfy the distribution requirements from Roth IRAs.
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