If a pre-RBD IRA owner dies; does the age 72 beneficiary have to take an RMD if they rollover the assets to their own IRA?

IRA Owner dies in September of 2021, pre-RBD. The 100% beneficiary spouse rolls over the IRA assets to her own IRA in December, she is age 72 in 2021, is she required to take an RMD in 2021? If so, would it be based on 12/31/20 account balance of the IRA owner?



No, the surviving spouse does not have an RMD requirement for the year of death when the IRA owner passed prior to RBD. While a spouse doing the spousal rollover is treated as the owner of the IRA for the entire year, this rule does not apply to the year of death. Therefore, unless the surviving spouse has owned her own IRA all along, she will not have any IRA RMD due for 2021. She will have a 2022 RMD based on the IRA value on 12/31/2021.

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