RMD Aggregation Rules and Appraisals for RMDs: Today’s Slott Report Mailbag

By Ian Berger, JD
IRA Analyst
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Question:

I am 72 years old and want to start taking RMDs. I have multiple accounts from teaching jobs that I had many years ago, plus a couple of traditional IRAs and a 401(k) with my current employer. Can I total all of these up as of December 31, 2021, and take an RMD based on that number, or does each account have an RMD based on its value?

Thank you for your help,

John

Answer:

Dear John,

The required minimum distribution (RMD) rules for aggregating retirement plan accounts are tricky. All of your traditional IRAs can be aggregated with each other, but not with your 403(b)s (from your previous teaching jobs) or your 401(k). This means that RMDs for each IRA account must be calculated separately, but the total RMD may be taken from one (or more) IRA account. Your multiple 403(b) accounts can also be aggregated with each other but not with your IRAs or 401(k). If your 401(k) plan uses the “still-working exception,” you do not have to take RMDs from that plan until you retire. At that point, the RMD for your 401(k) must be calculated separately and taken apart from your IRAs and 403(b)s. Considering all these moving parts, it might be wise to consider consolidation to minimize future RMD hassles.

Question:

I have a client that owns a business in his IRA. When he turns age 72, how is his RMD calculated? Does he need to value/appraise the business each December to determine the next year’s RMD amount? Thanks!

Answer:

Yes, he must obtain an annual appraisal of the business to determine each year’s required minimum distribution (RMD). The business must be appraised annually in order for the IRA custodian to report it to the IRS each year on Form 5498. The appraisal must be independent and legitimate so it can withhold scrutiny from the IRS if challenged.