3687 / How are the minimum distribution requirements met after the death of an IRA owner?

Prior to 2020, the minimum distribution requirements that applied after the death of an IRA owner depended on whether the IRA owner died before (see Q 3688) or after (see Q 3689) the required beginning date.

Distributions generally were treated as having begun in accordance with the minimum distribution requirements under IRC Section 401(a)(9)(A)(ii). If distributions irrevocably (except for acceleration) began prior to the required beginning date in the form of an annuity that meets the minimum distribution rules, the annuity starting date would be treated as the required beginning date for purposes of calculating lifetime and after death minimum distribution requirements.¹

1.   Treas. Reg. § 1.401(a)(9)-6, A-10; Treas. Reg. § 1.408-8, A-1.