Inherited IRA RMD question

I have a Client, Age-72, with a Traditional Inherited IRA who has taken it as her own. She is a Non-Spouse Designated Beneficiary. It is titled as:
Name
Inherited IRA
Bene of —–
Address

The Inherited Traditional IRA was received several years ago, so the year-of-death RMD was taken by the Decedent.

Client also has her own Individual Traditional IRA.

The Inherited Traditional IRA is in an Annuity, while the Individual Traditional IRA is with a Wire House.

The Client wants to keep the Inherited Traditional IRA intact and take the RMDs for both IRAs from the IRA at the Wire House.

The Wire House is refusing to provide/permit an RMD for the Inherited IRA, and is insisting that “IRS Regulations” requires that RMDs must be taken from each IRA.

After reviewing the 2017 Pub 590-B, I cannot find any mention that RMDs from Inherited IRAs must be taken from the Inherited IRA – spousal or non-spousal.

Page 12 of the 2017 Pub 590-B, upper left column, under the heading Miscellaneous Rules for RMD; second paragraph titled “More Than One IRA” states that RMDs from multiple IRAs can be taken from one IRA, as long as the total RMDs have been taken.

There is no mention of a difference between an Inherited Traditional IRA and a normal Traditional IRA.

Am I missing something – or is the wire house blowing smoke to preserve AUM???

The CPA is doubting my knowledge…

Please share your thoughts at your earliest convenience.

[email protected]



  • To be accurate, your client does not hold the inherited IRA as owner, she holds this IRA as beneficiary.
  • CFR 1.408-8 Q&A-9 addresses the issue and indicates that the RMD from the inherited IRA and the RMD from her own IRA cannot be aggregated which each other.  Each must satisfy its own RMD.  (https://www.law.cornell.edu/cfr/text/26/1.408-8):
  • Q-9. Is the required minimum distribution from one IRA of an owner permitted to be distributed from another IRA in order to satisfy section 401(a)(9)?
  • A-9. Yes, the required minimum distribution must be calculated separately for each IRA. The separately calculated amounts may then be totaled and the total distribution taken from any one or more of the individual’s IRAs under the rules set forth in this A-9. Generally, only amounts in IRAs that an individual holds as the IRA owner may be aggregated. However, amounts in IRAs that an individual holds as a beneficiary of the same decedent and which are being distributed under the life expectancy rule in section 401(a)(9)(B)(iii) or (iv) may be aggregated, but such amounts may not be aggregated with amounts held in IRAs that the individual holds as the IRA owner or as the beneficiary of another decedent. Distributions from section 403(b) contracts or accounts will not satisfy the distribution requirements from IRAs, nor will distributions from IRAs satisfy the distribution requirements from section 403(b) contracts or accounts. Distributions from Roth IRAs (defined in section 408A) will not satisfy the distribution requirements applicable to IRAs or section 403(b) accounts or contracts and distributions from IRAs or section 403(b) contracts or accounts will not satisfy the distribution requirements from Roth IRAs.

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