See attached Slott Report Article https://irahelp.com/slottreport/secure-20%E2%80%99s-biggest-mess-0

I think the IRS likely did not intend for a surviving spouse to have to elect to assume ownership in order to delay RMDs until the year deceased spouse would have reached RMD age, but the Secure 2.0 proposed amendments to Sec 401(a)(9)(B)(iv) of the tax code will do exactly that. Of course, the main benefit of Sec 327 is that a surviving spouse can make the election to be treated as the employee in qualified plans, which brings those plans into RMD parity with IRA accounts. That may reduce IRA rollovers.

In addition, I question the author’s conclusion that a surviving spouse who makes this election of ownership (ie treated as the employee) must use the decedent’s age for RMDs. While Uniform Table RMDs will not have to start before the deceased spouse’s RMD age, I don’t think the intent was to have to use the decedent’s age for RMDs rather than the age of the surviving spouse.

Comments?