1) She can use her life expectancy for both of them. The reason she can do this for her mother’s IRA is because her father passed before he was required to take RMDs as a beneficiary of her IRA. He was not required to take a beneficiary RMD until the year she would have reached 70.5. In this situation the client (successor beneficiary on Mother’s IRA) is treated as if she were the designated beneficiary.

2) Yes, because her RMD divisors would be the same for both IRA accounts, since for RMD purposes she is considered to have inherited both from her father. While in certain cases her divisor would be different and therefore the accounts should not be combined, in this case her divisor is the same EVEN THOUGH the original IRA owners were different. In most cases a successor beneficiary will not have the same divisor when they are a designated beneficiary on another IRA, but in this case the divisors are the same.

3) while they do not have to be kept separate, if they are kept separate for some reason, the RMDs can be aggregated because she inherited the IRAs from the same decedent. What is most confusing about this is that the IRS Regs only say that combination is possible if inherited from the same decedent, but they actually intend that to mean the same ORIGINAL DECEDENT. She did not inherit from the same original decedent, but for RMD purposes she is treated as if she DID, and that is what counts.

In fact, there would probably be less chance of having to explain this rationale to the IRS if the accounts were actually combined as opposed to keeping them separate but aggregating the RMDs.

• Flag as spam
• Log in to Reply