QDRO upon death of participant
Participant dies August 2016 with QDRO beneficiaries being two US citizen daughters and one French daughter and having not taken his RMD fully for 2016.. Firm holding QRDO did not make any RMD distributions to any daughter in 2016 stating no QDRO distributions were allowed until six (6) months after date of death (i.e. in 2017).
In 2017, a distribution was made of 1/3 of the value of the QDRO to the daughter in France. Subsequent distributions were made a differing times over the next few months to the remaining daughters (1/2 of the remaining balance as valued at time of the distribution to the next daughter and the balance to the remaining daughter at the value of the QRDO remaining weeks later).
QDRO firm states that the distribution in 2017 to first daughter carried out the remaining 2016 RMD to her and therefore no 1099rs will be issued to the two US daughters for 2016.
They further state that the substantial 1/3 distribution (sufficient to carry out the 2017 RMD for the daughters) to the first daughter that carried out the remaining 2016 RMD did not carry out the 2017 RMDs as they had not divided the QDRO into separate shares at year end 2016.
Question: Does the 2017 distribution to the first daughter also carry out the 2017 RMDs since she was the first beneficiary to received her 1/3 QDRO distribution?
Permalink Submitted by Alan - IRA critic on Wed, 2017-07-26 17:27
Sounds like the entire QDRO balance is being distributed to the beneficiaries in 2017. Therefore, any and all RMDs are satisfied. 1099R forms should be issued to each beneficiary reporting the amount that each of them received. I do not see why the separate account questions matter when a total distribution is being done. If only life expectancy RMDs were being distributed, the separate account rules would determine which of the beneficiary ages would determine the amount of the RMD, and the year the separate accounts were created would matter. But not if the entire balance is being distributed before year end 2017.