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Robert Bloink and William H. Byrnes

Retirement Planning > Spending in Retirement > Required Minimum Distributions

Don't Let RMD Relief Blind IRA Beneficiaries to the Big Picture

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What You Need to Know

  • Taxpayers who inherit IRAs have now been offered RMD relief for the fourth year in a row.
  • Delaying distributions may not be best for clients when their overall tax liability is considered.
  • It is unknown whether the IRS will extend the 10-year distribution window once its Secure Act regulations are finalized.

The Internal Revenue Service has once again stepped in to provide assistance to taxpayers who have inherited retirement accounts in the wake of the distribution changes made by the original Setting Every Community Up for Retirement Enhancement (Secure) Act and subsequent regulations.

The current distribution process governing non-eligible designated beneficiaries who inherit retirement accounts has proved to be both surprising and confusing. While the IRS has now offered relief for the fourth year in a row, taxpayers who are subject to the new rules should be advised with the big picture in mind. Delaying their distributions can offer current-year tax relief, but that may not be best for clients when their overall tax liability is considered.

The IRS has not given any indication as to whether it might scrap the RMD requirement for years one through nine entirely, so taxpayers should prepare to eventually take those distributions.

Secure Act Inherited Account Changes

Before 2020, retirement account beneficiaries could elect to stretch distributions from those inherited accounts over their own life expectancies. The Secure Act eliminated that option for most non-spouse beneficiaries. 

Now, beneficiaries who inherit retirement accounts must empty those accounts within 10 years of the original account owner’s death unless the beneficiary qualifies as an eligible designated beneficiary.

Under regulations that were proposed in 2022, the IRS interpreted the rule to require annual RMDs for non-eligible designated beneficiaries during years one through nine of the 10-year distribution period if the original account owner was already subject to the required minimum distribution rules at the date of death. Most had expected that beneficiaries could elect to take the entire account balance in year 10 if they choose.

IRS Waivers and Relief

Since the proposed regulations were released, the IRS has provided relief for beneficiaries each year by excusing those RMDs. Notice 2024-35 waives RMDs in 2024 for beneficiaries of accounts when the original owner died after the required beginning date and the beneficiary inherited the account in 2020, 2021, 2022 or 2023.

In previous notices, the IRS also excused these RMDs for 2021, 2022 and 2023 for account owners who died in 2020, but after their required beginning date, as well as for 2022 and 2023 for those who died in 2021, and in 2023 for those who died in 2022.

Under the new relief, beneficiaries of inherited IRAs, 401(k)s and 403(b)s will not be subject to any mandatory distribution requirements until at least 2025, so they also will not be subject to the penalty tax for missed RMDs if they elect to make no withdrawals during the relief period. Qualified plans will also not risk disqualification by failing to make one of these distributions.

The notice applies only to beneficiaries of inherited IRAs. Taxpayers who are subject to the lifetime RMD rules are still required to take distributions from their own accounts during their lifetimes. 

Clients and Their RMD Obligations

Notice 2024-35 indicates that the IRS may be ready to finalize the proposed regulations in the coming months. The agency specifically states that final regulations should apply for tax years beginning on or after Jan. 1, 2025. That means that beneficiaries of inherited accounts should prepare for enforcement of their post-Secure Act RMD obligations.

Although RMDs for inherited IRA beneficiaries have been waived each year since 2020, account beneficiaries subject to the 10-year rule may wish to consider taking annual RMDs anyway. Income tax rates are historically low, and the current ordinary income rates are set to increase after 2025 absent congressional action to extend the 2017 tax cuts. 

The IRS has not indicated whether it will extend the 10-year period to account for the years when RMD waivers were in effect. If it doesn’t, the beneficiary will be required to take larger RMDs to empty the account over a shorter period of time, meaning that the beneficiary could face a larger tax bill once the IRS begins enforcing RMD obligations.

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