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

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?

The Required Beginning Date is Now a “Really Big Deal”

When it comes to IRAs and workplace plans, the concept of the “required beginning date” (RBD) is a “really big deal” again. The RBD is the first date you’re required to start required minimum distributions (RMDs). For traditional IRAs, the RBD is April 1 of the year following the year you turn age 72. (But if you were born before July 1, 1949, your RBD was April 1 of the year after the year you turned 70 ½.) There are no lifetime RMDs for Roth IRA owners, so they are always considered to have died before the RBD with respect to their Roth IRAs.

ELIGIBLE DESIGNATED BENEFICIARIES AND DISTRIBUTIONS OF ROTH CONVERSIONS: TODAY’S SLOTT REPORT MAILBAG

Question: Hello, I inherited an IRA from my brother who passed away on January 6, 2022. His DOB was 12/31/1952. He had just turned 69. I am 75. My DOB is 6/26/1947. I understand the rules have changed regarding inherited RMD distributions recently and some accounts need to be depleted within a 10-year period.

ROTH CONVERSIONS AND INHERITED IRA RMDS: TODAY’S SLOTT REPORT MAILBAG

Question: Late in December, 2021, a taxpayer (under age 59 ½) takes a distribution of his (traditional, not Roth) 401(k), and has 20% withheld for Federal tax. Early in January, 2022, the full 100% of the distribution is deposited in a Roth IRA. Does this avoid the 10% penalty for early distribution? Is this reportable as a Roth conversion in 2022 or 2021?

How Are Roth 401(k) Distributions Taxed?

More and more 401(k) plans now offer Roth contributions. At the same time, Americans are changing jobs and receiving 401(k) distributions in record numbers. So, it’s a good time to review the tax rules that apply to Roth 401(k) withdrawals. (The same rules also apply to Roth 403(b) and Roth 457(b) withdrawals.)

The Limits of ERISA Spousal Protection

A recent federal court case from West Virginia illustrates that the spouse of a 401(k) participant usually has no right to prevent the plan from paying the participant a lump sum distribution. In Gifford v. Burton, a Mr. Gifford (his first name is omitted in the decision) was an optician at Walmart and a participant in the Walmart 401(k) plan. He was married to Sara Gifford, who was his sole beneficiary under the plan. In February 2021, Mr. Gifford received a distribution of all of his 401(k) funds and deposited those funds into an IRA. He then designated his daughter, Emma Gifford, as 90% beneficiary of his IRA and wife Sara as 10% beneficiary.

A Retirement Account Scorecard

Here’s a line from one of the manuals we use in our education seminars for advisors: “Missed stretch IRA RMD by an EDB, when the IRA owner dies before the RBD.” An old baseball expression says: “You can’t tell the players without a scoreboard.” In the world of retirement accounts, you can’t understand the rules without knowing the abbreviated terms. Here’s 18 common ones you should know:

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