what constitutes “sole beneficiary”

Submitted by Tom Railsback on Tue, 2015-04-28 19:00

I have an IRA that designates my QTIP trust as my primary beneficiary and which names my wife (age67)to receive all of the net income of the IRA during her lifetime or $5000 per month or the RMD whichever is greater. The contingent beneficiaries are my 4 daughters.

Does this qualify me to combine our ages in determining the Required Mandatory Distributions during my lifetime?



Submitted by Tom Railsback on Wed, 2015-04-29 15:06

I am 83 and my wife is 67. As I mentioned above she is the designated beneficiary of all of the net income of my IRA during her lifetime as stated in my Q Tip Trust. 4 children from a previous marriage are the contingent beneficiaries. Does that qualify her for “sole beneficary status so I can use both of our ages in computing my mandatory required distribution?

Submitted by Alan - IRA critic on Thu, 2015-04-30 03:43

You must use the Uniform Table, because your wife is not considered your sole beneficiary. The following is copied from IRS Reg 1.401(a)(9)-5:

Thus, for example, if the first beneficiary has a right to all income with respect to an employee’s individual account during that beneficiary’s life and a second beneficiary has a right to the principal but only after the death of the first income beneficiary (any portion of the principal distributed during the life of the first income beneficiary to be held in trust until that first beneficiary’s death), both beneficiaries must be taken into account in determining the beneficiary with the shortest life expectancy and whether only individuals are beneficiaries.

Submitted by Tom Railsback on Thu, 2015-04-30 15:58

Thanks Alan! I was sure that there was an actual caase or example where there was a Trust in which all of IRA  income was left to the wife during her lifetime with the contingent beneficaries being 4 children from a previous marriage and the fact the surviving spouse was entitled to all of the income qualified her as a “sole” beneficiary permitting the employee to use the joint table in determining his RMD.

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