Clients who inherited an IRA after 01/01/2020 have been exempt from RMDs until 2025. I want to use the appropriate factor. Let’s start by assuming the CARES act never changed the rules. A client inherits and IRA in 2020. The client is mandated to take their first RMD by 12/31/2021. Let’s assume they were 50 years old on 12/31/2021. Table 1 has a factor of 36.2. Every year we reduce the factor by 1, so 2025 it would be 32.2. We would take the 12/31/2024 value of the Inherited IRA divided by 32.2

Now, let’s assume the same facts with the current rules. Would this client have a factor of 32.2, or would I go to Table 1  and use the factor for a 54-year-old since this is the first year they must take a distribution? In other words, would I start with how old they were in 2021 and reduce it by 1 each year or use the factor for age 54 because this is the first year they are mandated to take an RMD?