74 year old daughter inherits mother’s IRA & Roth IRA

Submitted by Amanda Minter on Mon, 2022-11-14 20:55

As usual, I have begun second guessing myself after researching and need to confirm please! A 74 year old daughter inherited her mother’s IRA and Roth. Mom passed away on January 1, 2020 and was in her 90s.
I just wanted to confirm that both of these Bene IRA’s will be subject to the 10 year rule, so she will need to start taking annual RMD’s beginning in 2023 (since penalty was waived in 2021 and 2022). My confusion lies in the daughter herself being over 74, and does that change her being subject to the 10 year rule OR does her age cause her to need to take an RMD this year?
Your clarification is appreciated! Thank you!



Submitted by David Mertz on Mon, 2022-11-14 22:18

  • The inherited Roth IRA is not subject to annual RMDs.  The only requirement is that the inherited Roth IRA is fully distributed by the end of 2030 under the 10-year rule.
  • Under the proposed regulations, the daughter is subject to annual RMDs from the inherited traditional IRA for 2021 through 2029 (with penalty for failure to take RMDs for 2021 and 2022 waived, so it seems that RMDs for these years need not be taken) and final distribution by the end of 2030 under the 10-year rule.
  • The daughter’s age is only used to calculate the annual RMDs for the traditional IRA based the life-expectancy value from Table I using the daughter’s age attained in 2021, reduced by 1 for each subsequent year.
  • Even though waiver of the penalty suggests that she is not required to take a distribution from the traditional IRA this year, it might be sensible to take from the inherited traditional IRA in 2022 and beyond more than the calculated RMD amount so that there isn’t a large spike in taxable income in any one year.  Also, tax rates are scheduled to increase back to pre-2018 levels in 2026.

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