IRA Owner dies after attaining RMD age, but before April 1st of the year following the year they reached RMD age

We have a client who inherited an IRA from their dad. The dad’s birthdate was in October of 1949 and his date of death was in March of 2022. The dad reached aged 72 (his RMD age is 72) in October of 2021. He was not required to take his first RMD (for the year 2021) until April 1st, 2022, but he passed before that deadline. The beneficiary did take the dad’s 2021 RMD. A couple of questions about when the beneficiary has to take RMDs.

  1. In that example, has the dad passed his RBD?
    1. If so, that would mean the beneficiary would have to take RMDs in years 1-9 and distribute the entire balance by the end of year 10.
    2. If not, that would mean the beneficiary would only have to distribute the entire balance by the end of the 10th year.
  2. Does the answer to question 1 change if the dad had taken his first RMD while he was living (anywhere between October 2021 – March 2022).

I guess the question boils down to this. Does the Account Owner reach their RBD (and has “turned on RMDs”) on the date they turn RMD age, or does the Account Owner reach their RBD on April 1st of the calendar year after they reach RMD age?



Let me rephrase the last sentence.

Is the account owner said to have started RMDs…

on the date they reach RMD age?
–or–
on April 1st of the year after the year the account owner reaches RMD age (RBD)?

–or–

on the day the account owner takes their first RMD (assuming it is before April 1st of the year after the year the account owner reaches RMD Age)?

The decedent passed prior to his RBD whether he took RMDs for 2021 or 2022 before passing or not. As such, there are no annual beneficiary RMDs in years 1-9 of the 10 year rule. That said, it may not be wise to defer all distributions to the last couple of years which would result in a large taxable distribution.

Moreover, because death was prior to RBD, the RMD that would have been due had he lived to the actual RBD date is erased, therefore there is no year of death RMD for the beneficiary to worry about.

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