I was looking at the revised Pub 590-B for the first time today, and was grateful to see that the Service clarified that a designated beneficiary does *not* have to take stretch RMDs for years 1-9 before lumping out in year 10.

I was also glad to see that they clarified that an EDB can opt for the 10-year rule if they wish. However, in that same paragraph, it’s stated that a surviving spouse EDB cannot opt for 10-year if the deceased IRA owner was past RBD. That had me scratching my head.

SECURE’s changes to 401(a)(9) make it clear that the 10-year rule applies to designated beneficiaries even if the decedent had hit RBD before they died. Why would the Service allow a SS to take the 10-year only if the deceased spouse hadn’t hit RBD before they died? Why would they make the 10-year option more restrictive for a SS than, say, a bene that was the decedent’s best friend?

I can kind of see the circular logic of subsections B and H in 401(a)(9), but it still seems weird that a SS could not use 10-year if the deceased spouse had lived past RBD.

Am I missing something here? The language in question is on page 11 of the Pub, left-hand side under the header “10-year rule”.

Please and thank you.