Successor Roth RMD requirements
We are having difficulty determining if a successor beneficiary Roth account is subject to annual RMDs. Here are the details:
Maryellen is the original Roth IRA owner who passed in 2011 at age 69.
Karen is Maryellen’s daughter and had a beneficiary Roth account. She took annual Roth RMDs under the old stretch rules from 2012-2023.
Karen died in 2023 at age 58.
Mark is Karen’s spouse. He is the successor beneficiary of the Roth.
One opinion is no RMDs:
Even though Karen was taking RMDs based on pre-secure act rules, Mark is now the successor bene Roth account owner and has 10 year rule with SECURE Act rules (No RMD because Maryellen passed before RBD).
Another opinion is Yes to RMDs:
When Karen died in 2023, her successor is now subject to the 10-year rule and must continue taking bene RMDs in years 1 – 9 using Karen’s remaining single life expectancy under the IRS “at least as rapidly as the IRA owner / beneficiary” was taking distributions.
Your opinion would be greatly appreciated!
Permalink Submitted by Alan - IRA critic on Mon, 2024-02-05 22:10
The proposed Secure Act Regs (p 47) only mention annual RMDs for successor beneficiaries if the owner passed after RBD, and Roth owners all pass prior to RBD. Apparently, the IRS is applying the “at least as rapidly” concept to the original owner only, and therefore neither designated 10 year rule beneficiaries of a Roth IRA or their successor beneficiaries need take annual RMDs in years 1-9 of the 10 year rule.