RMD’s for IRA BDA’s under 10 Year Rule

Hello,

Just a follow on the 10 year rule with IRA BDA’s for non-eligible designated beneficiaries, is there any indication that the IRS will have a final confirmation if RMD’s will need to be taken in 2023?

Thank you.



It’s not clear when the final Regs will be released, but I would expect them by no later than Sept to avoid another year of uncertainty near year end. There is little indication that they will reverse course once again and another reversal would be very embarrassing for the IRS.  To be clear, 10 year rule beneficiaries will not have to take annual RMDs if death was prior to RBD, and it’s 95% certain that they will if death was on or after RBD. These positions were clear in the proposed Regs released 15 months ago.



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