Can You Wait Until April 1, 2022, To Take RMD From IRA Inherited In 2021?

In a previous Forbes post on inherited IRAs, I discussed the importance of making sure an RMD (required minimum distribution) was taken before the end of the year by a person inheriting an IRA (individual retirement account) if the IRA owner died and had not taken his or her required distribution for the year.

The following letter (from a non-spouse beneficiary) asks questions related to this type of situation.

A.C. wrote:

“My 96-year-old father died Oct 12, 2021. He scheduled his RMD on 12/15 of every year. As the new owner of the inherited IRA—do I have to take an RMD in 2021 based on a 10-year schedule or do I have until April 1, 2022 to take an RMD? Or can I set the schedule for the RMD based on a 10-year plan to fully distribute the IRA. A beer rides on the answer to these questions about the required date to take the RMD. Thanks.”

First, Definitions

If You Inherit an IRA, You Are Not the Owner. When you inherit an IRA from a non-spouse, you are not the “new owner” of the IRA. You are the beneficiary of the inherited IRA. You’ll see why this matters momentarily. (Exception: A spouse who inherits an IRA can become the new owner of the IRA if he or she chooses to treat the IRA as his or her own.) A.C. is the sole beneficiary of his father’s IRA.

April 1 Rule Applies to Owners, Not Beneficiaries. The April 1 rule applies only to owners and only to the owner’s very first RMD, which would normally be at age 72. So, A.C., if you were betting on April 1, 2022, sorry. (Of course, double-check with your tax adviser before giving up on the beer.)

The 10-Year Schedule Does Not Apply to the Owner’s Year-of-Death RMDs. The SECURE (Setting Every Community Up for Retirement Enhancement) Act’s 10-year schedule, which A.C. is referring to in his email, applies to subsequent years, not the year of death — more on that in a subsequent post.  

Owner’s Final RMD. When an IRA owner dies before withdrawing 100% of his or her RMD, someone needs to direct that the shortage be withdrawn before the close of the year. That someone is usually the beneficiary; the shortage needs to be withdrawn by Dec. 31, 2021, if the death occurred in 2021.

That means someone in A.C.’s position needs to check with the custodian of his father’s IRA now, well before Dec. 31, 2021, to confirm that this rule applies in his case, and to get instructions on how to proceed.

Second, Resources

Your go-to resource for answers on inherited IRAs is IRS Publication 590-B, specifically the section titled “Distributions in the year of the owner’s death.”

There you will see that if the owner died on or after the date he or she was required to start taking RMDs, “the IRA beneficiaries are responsible for figuring and distributing the owner’s required minimum distribution in the year of death. The owner’s required minimum distribution for the year of death is generally based on Table III (Uniform Lifetime) in Appendix B.”

Again, the owner of the IRA is the deceased person you inherited the IRA from. The beneficiary is you, the person who inherited the IRA.

Note also that when the death occurs during the calendar year is not relevant: “You figure the required minimum distribution for the year in which an IRA owner dies as if the owner lived for the entire year,” according to a note at the end of the IRS Publication 590-B section mentioned above.

Third, Don’t Do This Without Your Tax Adviser

As always when dealing with an IRA RMD, consult with your tax adviser for the best way to proceed. Tax situations are unique to the taxpayer.

In a later post, we’ll return to the two references A.C. made in his email to other RMD requirements.

Questions?

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