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RMDS FOR ANNUITIES AND SPOUSAL BENEFICIARY RULES: TODAY’S SLOTT REPORT MAILBAG

Question:I have an IRA holding an immediate annuity as well as other IRAs. With the passage of the SECURE 2.0 Act, l understand that I may be able to apply my monthly annuity payments against my RMD requirement for all of my IRAs. The only valuation I can get on my annuity is the year-end fair market value. Can you provide any update to any IRS ruling on this?

What Are My Contribution Limits If I Participate in Two Company Savings Plans?

You probably know there’s a limit on the amount of pre-tax and Roth contributions you can make to your company savings plan each year. The 2025 elective deferral limit is $23,500 for 401(k), 403(b) and 457(b) plans and is either $16,500 or $17,600 for SIMPLE plans (depending on the size of your employer). If you’re age 50 or older, you can make additional catch-up contributions beyond these limits, and if you’re age 60, 61, 62 or 63, you may qualify for even higher catch-ups.

Holiday Cheers and Wishes

This is the time of year for good cheer and holiday wishes. In keeping with those traditions, here are some cheers and wishes for the IRS and Congress:

A Way to Jump-Start 529-to-Roth Rollovers

We have covered in The Slott Report the new SECURE 2.0 provision that allows unused 529 plan funds to be rolled over to Roth IRAs. It originally appeared that this new rule was to be effective for 2024. However, the IRS has now said that rollovers done before April 15, 2024 can count as Roth IRA contributions for tax year 2023 if the 529 beneficiary has not already maxed out on his 2023 IRA contribution limit.

THE PRO-RATA RULE AND INHERITED IRA RMDS: TODAY’S SLOTT REPORT MAILBAG

Question:I was given your information by a financial advisor who follows your articles. I have a unique situation with a client who is a high earner with several old 401(k) accounts. My idea was to have her fund an IRA with a contribution for 2023 and 2024. Then I was going to have her do the Roth conversion with no tax liability. She currently has no IRAs. My question is: If I roll over her 401(k)s later in 2024, would she still be subject to the pro-rata rule? When I contacted my back office, they said that at the time of conversion she will not have an IRA, so she should be all set. However, my thought is that the pro-rata rule applies on a calendar year basis, so she would be subject to the pro-rata IRA rule.

More 401(k) SECURE 2.0 Changes Already in Effect – And On the Way

By now, you probably know that a number of SECURE 2.0 provisions pertaining to 401(k) (and other company savings plans) became effective this year. We’ve already discussed two of them in The Slott Report. The first is that Roth 401(k) accounts, like Roth IRAs, are now exempt from RMDs.

How the Contribution Limits Work When You’re in Two Plans

The start of the new year is a good time for a refresher course on the contribution limits that apply when someone is in two different retirement plans at the same time or at different times within the same year (e.g., after changing jobs). The rules are challenging because there are two different contribution limits to worry about – the “elective deferral limit” and the “overall contribution limit.”

How the Contribution Limits Work When You’re in Two Plans

The start of the new year is a good time for a refresher course on the contribution limits that apply when someone is in two different retirement plans at the same time or at different times within the same year (e.g., after changing jobs). The rules are challenging because there are two different contribution limits to worry about – the “elective deferral limit” and the “overall contribution limit.”

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