SECURE Act 2.0 – Surviving spouse using deceased age for RMD

Submitted by Sandra Presgraves on Tue, 2023-01-17 23:44

According to SECURE Act 2.0, for the surviving spouse to use the deceased spouse age for the RMD, do the funds need to be in an Inherited IRA to take advantage of this provision?



Submitted by Alan - IRA critic on Wed, 2023-01-18 01:45

  • While it is not clear, I don’t think Sec 327 allows the SS to use the deceased spouse’s age other than to determine the year Uniform Table RMDs must begin, which is the year in which the deceased spouse would have reached RMD age (now 73).  This interpretation conforms with how one major benefits firm describes this section as intending to extend IRA rules to qualified plans with respect to the spousal rollover. IRA owners have never been allowed to use the Uniform Table with someone else’s age. In other words, the SS is treated as the employee but must use their own age for RMDs. Also, the old rule that allows a surviving spouse to take beneficiary RMDs using the single life table using the deceased spouse’s age still applies, but the age of the SS would have to exceed that of the deceased spouse by many years for a beneficiary RMD to be lower than a Uniform Table RMD.  
  • The intent of Sec 327 is to provide parity with respect to surviving spouses of employees with the options they have with inherited IRAs, that of assuming ownership and using the Uniform Table.
  • Secure 2.0 improves the attractiveness of qualified plans relative to IRAs, increases Roth contribution options, and also favors annuitization of account balances among other enhancements.


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