RMD AGE

client passed away age 74- DOB 12/1/1946 and we are assisting beneficiaries which are the kids (non-spouse) with IRA rollover. Please confirm if RMD must be distributed before rollover to the inherited IRA.

thanks



The year of death RMD should be completed by the end of the year of death by any beneficiaries. The beneficiaries must create inherited IRAs, and can then either complete the mutually agreed share of the RMD before transferring to another custodian, or they can transfer and complete it from the new custodian’s inherited IRA. The mutually agreed share might be 0 for some beneficiaries because others want to distribute more for spending needs. As long as the total RMD is completed by the decedent and their beneficiaries by year end, the IRS is happy. If a beneficiary does not trust the follow through of others to take a pre agreed amount of the RMD or if there are simply too many to coodinate, or they are not communicating, the IRS has never been known to take any action against a beneficiary who takes out at least their share. For example, if there are 4 equal beneficiaries, any of them can take 25% of the remaining RMD, and even if one of them does nothing, the IRS will not penalize the ones who took their 25% share.  In short, they do not have to pro rate, but in some cases it is the simplest approach. 
The separate account rules do not mean that much after the Secure Act because most beneficiaries are subject to the 10 year rule. However, if one of these beneficiaries was disabled (an eligible designated beneficiary), the separate accounts need to be created by the end of the year after the year of death. The disabled beneficiary can then stretch over their life expectancy, and the others get the 10 year rule.

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