MRD calculation when spouse is over 10 years younger

Husband’s (age 87) IRA primary beneficiary designation is a QTIP trust provision (for his wife age 72) within a Revocable Living Trust that becomes Irrevocable upon his death. Can we look through the trust to the age of his wife now while the husband is alive in order to calculate the MRD amount?



Probably not. Accessing Table II (joint life) requires a sole spousal beneficiary. The only type of QTIP trust that would meet the “sole” requirement would be a conduit QTIP trust because the RMD and any distributions in excess of the RMD can only be paid to the surviving spouse during that spouse’s life time. Other more common forms of a QTIP trust result in restrictions in distributions to the surviving spouse (usually to income and small amounts of principal)  that benefit the remainder beneficiaries of the trust. See IRS Reg http://www.law.cornell.edu/cfr/text/26/1.401%28a%29%289%29-5, Q&A 7, Example 2.



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