Interesting subject that our firm is experiencing for the first time. We have a divorced couple: wife turned 72 in August of 2022 and husband turned 71 in 2022. The couple notified the firm of their divorce in 2022. Per the divorce decree, half of husband’s IRA assets were to be transferred to an IRA in the wife’s name. The husband’s IRA was not split by the custodian until January 2023. Would the wife be subject to an RMD in 2023? Our firm’s understanding is that because RMDs are based on the 12/31 balance of the previous year, she would not be subject, as assets weren’t in her account until January 2023. Obviously the husband would not have an RMD due with the SECURE Act extending the RMD start age to 73.

For the sake of learning, if the wife already had an IRA at another custodian (existed well before the divorce) and the same fact pattern above holds, would it affect things? Again, our understanding is that only an RMD on the existing IRA at custodian #2 would be applicable in 2023 and the assets in the “divorce” IRA would not affect the RMD at custodian #2.

Thank you in advance for the guidance!