SECURE - natural non-EDB inherits after RBD

Submitted by Robert Vashko on Wed, 2020-11-25 18:20

Just crossing my “t”‘s on this:

IRA owner “Mom” dies in 2020 at age 75, having already hit RBD. Sole primary bene is Daughter, who does not meet any of the criteria to be deemed an EDB under SECURE.

I know that pre-SECURE, the stretch RMDs in such situations were supposed to be based off the longer of the two life expectancies.

But post-SECURE, since Daughter’s life expectancy is moot, what are her distribution options (other than lump-sum or annuitization)? Is out-in-10 the only option for her? Or does she have the option of taking Mom’s Table III RMDs instead?

Please and thank you!

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Permalink Submitted by Alan - IRA critic on Wed, 2020-11-25 18:59

The 10 year rule is the only option, and it no longer matters whether Mom passed prior to RBD or after per Sec 401(a)(9)(H)(i)(II).
The gray area would be if Mom left the IRA to her older sister, an EDB. It is not entirely clear, but generally presumed that the older sister could use the LE of Mom since Mom passed after her RBD and has a longer LE than the older sister beneficiary.