Second generation Inh IRA & First Generation Inh IRA and RMDs

I have a client who has an inherited IRA account she inherited from her mother that was her mother’s own personal Traditional IRA before her death. This client also inherited from her mother, an inherited IRA that her mother had previously inherited from her deceased partner when he died in 2010. The mother was taking RMDs from the inherited IRA she had from her deceased partner based on the rules (reducing life expectancy factor by 1 each year) and so it is my understanding that the mother’s daughter, who is my client, must as the new beneficiary on that twice-inherited IRA, continue the schedule of RMDs that her mother was using; that is, no recalculation for my client’s life expectancy. Is that correct?

All that to ask, does each of these IRAs require that the RMD be taken from the actual account on which the RMD was calculated, or like with a client who has multiple Traditional IRA accounts, can the RMD calculated on “all” inherited IRA accounts be taken from just one of the inherited IRA accounts? My client elected to receive a death benefit distribution from a Traditional IRA account of her mother’s directly and did not take it in an inherited IRA account. The amount on that distribution more than covers the RMDs as calculated on all inherited IRAs. Can it satisfy the RMDs for all the inherited IRAs owned?



  • You are correct about the previously inherited IRA which she inherited from her mother. Client must continue the RMD schedule of her mother which includes the 1.0 annual reduction.
  • The second question is tougher. The IRS Regs indicate that RMDs can be aggregated for inherited IRAs from the same decedent, however this Reg (1.408-8  Q 9) refers to the tax code section that deals only with designated beneficiaries. Since the client is the designated beneficiary on only the IRA inherited directly from her mother, the RMD for that IRA cannot be aggregated with the RMD for which the client is only the successor beneficiary and NOT a designated beneficiary. And this makes sense because the RMD divisors are different. With different divisors, a beneficiary could draw down the IRA with the largest RMD % first and preserve the balance in the inherited IRA with the lower RMD %. As a result this practice would result in more tax deferral than the RMD rules intend.

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