Permalink Submitted by Alan Spross on Mon, 2009-05-04 21:42
Tom is correct about the non spouse rules applying here. However, the RMD for the two inherited IRAs CAN be aggregated providing life expectancy distributions are being applied to both of them, since they were inherited from the same decedent. Here is a copy of the IRS Reg.addressing this. Note the 3rd line:
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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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Also note that aggregation of the RMD does not always mean that the two inherited IRA accounts can be combined by transfer into a single account. In certain cases, the RMD divisor can be different for the two IRAs. In this situation, the RMD can still be aggregated, but the accounts should not be combined because the account balance that the different divisor applies to will no longer be determinable.
Permalink Submitted by James O'Brien on Mon, 2009-05-04 18:13
Traditional and inherited from her ex-husband.
Permalink Submitted by Alan Spross on Mon, 2009-05-04 21:42
Tom is correct about the non spouse rules applying here. However, the RMD for the two inherited IRAs CAN be aggregated providing life expectancy distributions are being applied to both of them, since they were inherited from the same decedent. Here is a copy of the IRS Reg.addressing this. Note the 3rd line:
>>>>>>>>>>>>>>>>>>>
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.
>>>>>>>>>>>>>>>>>
Also note that aggregation of the RMD does not always mean that the two inherited IRA accounts can be combined by transfer into a single account. In certain cases, the RMD divisor can be different for the two IRAs. In this situation, the RMD can still be aggregated, but the accounts should not be combined because the account balance that the different divisor applies to will no longer be determinable.