Pre-SECURE Inherited IRA – Calculate new RMD

Submitted by John McGlothlin on Mon, 2022-02-14 20:38

I have an inherited IRA established in 2010; the original IRA owner was my father.

I have been taking RMDs based upon the life expectancy of my brother. This is because we did not establish separate inherited IRAs before the deadline of Sept. 30 following the year of death, and so had to take RMDs based upon the life expectancy of the oldest of the three beneficiaries (my brother).

I know I need to recalculate the RMD for this year by retroactively applying the new life expectancy tables starting the year after death. But should I continue to use my brother’s life expectancy? Or can I use my (much longer!) life expectancy?



Submitted by Alan - IRA critic on Mon, 2022-02-14 21:35

You must continue to use his LE as the oldest beneficiary if the separate accounts were not established by the deadline, but that deadline was 12/31 of the year following the year father passed. That’s 3 extra months, but you may not have met that deadline either. Any chance that YOUR separate account was created by that deadline?

Submitted by John McGlothlin on Mon, 2022-02-14 22:51

My records say that my account was established as of Dec 10 of the year following the year of death. Must all of our accounts (my two siblings and mine) have been established by 12/31? The other wrinkle is, my records say that in the year after death I received an RMD that was based upon my brother’s life expectancy; this was before I established my own inherited IRA. I frankly can’t remember why that was handled that way. 

Submitted by Alan - IRA critic on Tue, 2022-02-15 17:57

Pub 590 B states under “multiple individual beneficiaries” that the age of the oldest beneficiary applies to all if the account has not been divided into separate accounts for each beneficiary. This unofficial paragraph is the only place where “each” is used with debatable interpretation of it’s meaning.
RMD regulations for IRAs defer to those of qualified DC plans if not otherwise stated. The applicable Reg on separate inherited accounts for DC plan beneficiaries is addressed in Reg 1.401(a)(9)- 8, QA 2. In this Reg separate accounts are defined in term of each separate account that has been created by the deadline.
Therefore, I believe that you have been taking higher than required RMDs since 2011, and you could have been basing your RMD on your own age, not the age of an older beneficiary. Distributions you have already taken cannot be undone even though some portion was greater than your individual RMD. But when you “reset” to the new table I suggest that you use YOUR own age attained in 2011 to determine the divisor under the new table, then reduce that divisor by 1.0 for each year since 2011. That will reduce your beneficiary RMD from 2022 forward.

Submitted by John McGlothlin on Tue, 2022-02-15 22:10

Thank you! I really appreciate the input.

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