Disabled or chronically ill persons to be EDBs

Have a client whose mom passed 1/1/2020. He is disabled & has been taking RMDs as a Non-EDB person. That is as per the 10 yr rule. Since he is disabled/chronically ill, does he need to document his aflliction in a particular way such that the IRS will allow him to stretch the inherited IRA RMDs? Thank you



Was he receiving SSD at the time of her death or have documentation from an MD that he met the disability requirement per Sec 72(m)(7) at the time of her death?

The recently released IRS final Secure Act Regs have removed the documentation requirement for IRA beneficiaries, so the failure to provide the IRA custodian with that documentation by 10/31/2021 should no longer prevent him from being treated as an EDB rather than a 10 year rule beneficiary. Therefore, he basically is on the honor system due to this unexpected reprieve.

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