MRD for Inherited IRA

I could use some guidance. My client died at the age of 99 on 1-20-2020.
His IRA was split between two of his children, both under the age of 72, not that that matters much anymore.
No distributions were made during the calendar year 2020 and 2021 from the inherited IRAs.
Normally, both would have to withdraw over a ten year period of time with withdrawal being made each and every year.
How do I deal with the fact that no distributions were made during 2020 and 2021 to either of the adult beneficiaries.
Do we start a new 10 year withdrawal policy beginning in 2022?
Or in the alternative, do we now have 8 year to reduce the account to zero?
Assuming both of my clients are 66 years old, do I use the single life table based upon the current age?

Any guidance would be appreciated.

Bob Maloney, napfabob, 603-968-2317



  • 2020 RMDs were waived by the CARES Act for both owners and beneficiaries, and the IRS has just waived the penalty for not taking 2021 and 2022 distributions for 10 year rule beneficiaries when the owner passed after their RBD. Therefore, nothing needs to be done through this year. If the IRS proposed Regs are adopted, the IRS will have to clarify whether annual beneficiary RMDs will have to start for 2023, and if those RMDs will include making up the 2021 and 2022 RMDs as well. Either way, these inherited IRAs must be drained by 12/31/2030.
  • The most likely version of the final Regs, when issued will be that the beneficiaries will have to start annual RMDs in 2023. Their divisor would be determined by their age in 2021 using the new RMD tables, then subtracting 2.0 from that divisor to determine the 2023 divisor, then continuing to reduce the divisor by 1.0 each year. That said, they may wish to take out more than these RMDs so that they are not faced with a very large distribution in 2030 that may spike their marginal rate that year.

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