IRS Issues New RMD Life Expectancy Tables

The Internal Revenue Service recently issued new RMD (required minimum distribution) life expectancy tables to be used by account owners and beneficiaries to calculate RMDs from traditional IRAs and other retirement accounts. The new tables are effective for RMDs taken after 2021.

Those who take only the minimum amount required by the IRS each year will see smaller RMDs each year and greater opportunity for tax deferred growth.

There are 3 life expectancy tables used to calculate RMDs:

Uniform Lifetime Table. This table is used in most cases by an owner of a traditional IRA or other tax deferred retirement account. It does not matter whether the account owner is single or married. (Owners of Roth IRAs are not subject to minimum distribution rules.)

Joint & Last Survivor Table. This table is used primarily by an owner of a traditional IRA or other taxable retirement account if the owner’s spouse is the sole account beneficiary and is more than 10 years younger than the account owner.

Single Life Table. This table is used by the beneficiary of an inherited retirement account (traditional or Roth) if: a) the account owner died before January 1, 2020; or b) the account owner died after December 31, 2019, and the beneficiary is an eligible designated beneficiary (EDB). An EDB is a surviving spouse, a minor child, a disabled or chronically ill individual, or an individual not more than 10 years younger than the deceased account owner. An individual who does not qualify as an EDB must liquidate the entire balance of an inherited account within 10 years of the year of the account owner’s death.

Remember, the new tables must be used to calculate annual RMDs taken after calendar year 2021. Roth IRA owners are not subject to RMD rules, but Roth IRA beneficiaries are. Regardless of the type of account, RMDs are not required for 2020.

You may read the IRS publication here.

Having difficulty calculating RMDs or managing distributions from a retirement account? Give me a call, I can help.

Inheriting an Inherited IRA – It’s complicated!

In my last post, I outlined the key points to keep in mind when dealing with an inherited IRA. Unfortunately, the discussion may not end there. You may be the successor beneficiary of a previously inherited IRA.

In this situation, the IRA or other account was inherited by a prior beneficiary following the account owner’s death. Oftentimes the original account beneficiary will pass away before the IRA is completely liquidated. If that is the case, the successor beneficiary must know how the distribution rules will impact her.

The analysis begins by determining the date the original beneficiary inherited the IRA. (This is the date of the IRA account owner death.) Under current tax rules, if the IRA’s original beneficiary inherited the account on or before December 31, 2019, the distribution rules applicable to a successor beneficiary will differ from the rules that will apply if the original beneficiary inherited the IRA after December 31, 2019. Let’s look at each situation:

Did the original beneficiary inherit the IRA on or before December 31, 2019? If so, the successor beneficiary will have 10 calendar years following the year of the original beneficiary’s death to completely liquidate the IRA. This 10 year liquidation period will apply to any individual named a successor beneficiary. For instance, if the successor beneficiary is the original beneficiary’s spouse, he or she must liquidate the entire balance of the IRA with the 10 year term.

The successor beneficiary is not required to withdraw a minimum amount each year during the term. She may wait until the very end of the term to liquidate the IRA. The IRS will penalize her if she does not fully liquidate the account by the end of the 10 year term. The penalty will be equal to 50% of the balance remaining in the IRA at the end of the term. The IRS will levy the penalty each year until the IRA is liquidated.

Did the original beneficiary inherit the IRA after December 31, 2019? If the original IRA beneficiary inherited the account after December 31, 2019, the distribution rules applicable to the successor beneficiary will depend upon the status of the deceased original beneficiary at the time of his death. If the original beneficiary was an “eligible designated beneficiary,” or “EDB” (defined by the tax code), the successor beneficiary will have 10 years from the year of the original beneficiary’s death to liquidate the IRA.

An EDB may be: a) the surviving spouse or a minor child of the account owner: b) a disabled or chronically ill individual: or c) an individual not more than 10 years younger than the deceased account owner. The tax code deems all other individual beneficiaries to be “designated beneficiaries.” (A successor beneficiary will never be an EDB under the tax code.)

If the original IRA beneficiary was merely a designated beneficiary, then the successor beneficiary has only the remainder of the original beneficiary’s 10 year term to complete the IRA liquidation. She does not get a new 10 year term to liquidate the IRA.

Again, the required minimum distribution rules do not apply. However, the IRS will impose the 50% penalty if the account is not fully liquidated by the end of the original beneficiary’s 10 year term. A successor beneficiary will have to move quickly to liquidate the IRA if the original beneficiary died late in the last year of the 10 year term.

One must be on their tippy-toes in any situation involving an inherited IRA or other retirement account. She must be especially careful if inheriting a previously inherited IRA.

If you or someone you know is struggling to manage an inherited IRA or other retirement account, give me a call. I can help.

A Few Pointers About That IRA You Just Inherited.

According to Forbes Online, the largest private transfer of wealth will take place over the next 30 – 40 years as members of the Baby Boomer generation pass their wealth on to younger generations. Some estimates are that $30 trillion will change hands. A large portion of that wealth is held in tax deferred or tax free IRAs (traditional and Roth and other tax deferred retirement accounts. If you inherit an IRA, and aren’t the surviving spouse, there are major rule differences that you must heed.

First, the rules that govern distributions from an inherited IRA will differ depending upon the beneficiary’s classification. If the account owner died after December 31, 2019, only an “eligible designated beneficiary” may take distributions from an inherited IRA over her remaining life expectancy. Individuals who are “eligible designated beneficiaries” under the tax code are: a surviving spouse; a minor child; a disabled individual; a chronically ill individual; or an individual not more than 10 years younger than the deceased account owner. If you do not fall into one of those categories, you are deemed to be a “designated beneficiary,” and you must liquidate the entire balance of the inherited IRA (traditional or Roth) within 10 years of the year of the account owner’s death.

As a designated beneficiary, you are not required to take periodic distributions (such as an annually) from the account. The tax code merely requires that all of the money be withdrawn by December 31 of the 10th year following the year of the account owner’s death. You can wait until the very end of the liquidation window before withdrawing the balance of the account. But remember, if the account is a traditional IRA, distributions will be taxable income to you, so it may make sense to take periodic distributions to reduce the income tax bite. Distributions from an inherited Roth IRA are not income taxable.

Second, you cannot roll over an inherited IRA like you can your own account. While you inherited the account, you are not considered the account owner under the tax code. That is why the deceased owner’s name must be on the account title “for the benefit of” the beneficiary. If you do try to roll a traditional IRA over into an account in your own name, you have made an irreversible taxable distribution! So too with an inherited Roth IRA. While the distribution may not taxable, it cannot be reversed. All the potential future tax-free growth will be lost.

However, you may directly transfer an inherited IRA from one custodian to another. In this type of transfer, the account balance is sent directly from the old custodian to the new one. Caution! – You cannot directly transfer money from an inherited IRA to your own IRA in hopes of avoiding the rollover prohibition. The IRS will consider that to be an irreversible distribution as well.

Third, you cannot contribute to your inherited IRA. If you would like to put money away for your retirement, you will have to open your own IRA.

Fourth, if you are under age 59½, the 10% early withdrawal penalty will not apply to distributions from your inherited IRA. The rule does not apply to forced distributions from an inherited account.

Finally, you cannot convert your inherited traditional IRA to a Roth. Not only is this deemed to be an irreversible taxable distribution, but the funds cannot then be deposited into a tax-free Roth account. Any future earnings on the remaining balance will be subject to taxation.

If you are struggling to manage your inherited IRA, give me a call. I can help.

COVID-19 Bill Eases Rules for Retirement Accounts.

The COVID-19 stimulus (CARES Act) signed by President Trump last week includes some important tax relief for older retirement account owners.

First, The required minimum distribution (RMD) rules for Individual Retirement Accounts and 401(k)s are waived for 2020. If you haven’t taken your RMDs for 2020 yet, or have some RMDs left to take, you can leave the money in the account. The waiver applies to inherited retirement accounts as well.

This could be a bigger benefit than one might think. A 2020 RMD is based upon the account’s value as of December 31, 2019. If the value of a retirement account took a nose dive, the 2020 RMD (based upon a pre-correction value) would take a larger percentage of the account’s current value than otherwise would have been taken but for the correction. This waiver will give one’s retirement account a chance to recover without having the depletion caused by a forced RMD.

In addition, the IRS has extended the tax-filing deadline for 2019 federal income tax returns from April 15 to July 15. The extension postpones the deadline for making a prior-year contribution (for 2019) to a traditional and Roth IRAs to July 15. Be sure to indicate to the IRA custodian that the amounts contributed before July 15, 2020, are a 2019 prior-year contribution.

The CARES Act also waives the 10% pre-age 591/2 early distribution penalty on distribution of up $100,000 from IRAs and other retirement plans for individuals who meet the requirements of being affected by the coronavirus. Income taxes would still be due on pre-tax distributions, but could be spread evenly over three years, and the funds could be repaid anytime during the three years. Finally, rules for plan loans are relaxed for those who meet the definition of being affected by the coronavirus. Loan limits are increased and repayments postponed.

If you need assistance with your financial or retirement planning, give me a call, I can help.

Stay safe; wash your hands frequently!

Taking a Closer Look – The SECURE Act’s “Eligible Designated Beneficiary.”

The Setting Every Community Up for Retirement Enhancement (“SECURE”) Act became law on January 1, 2020. The SECURE Act made major changes to the distribution rules governing inherited IRAs (both traditional and Roth) and company sponsored retirement plan accounts. In general, the Act requires a designated beneficiary of an inherited retirement account to withdraw the entire balance from the account within 10 years of the year of the original account owner’s death if the account owner dies after December 31, 2019.

However, the SECURE Act carved out a class of beneficiaries who remain eligible to take distributions from an inherited retirement account using the old life expectancy rules. Beginning January 1, 2020, an individual who qualifies as an “eligible designated beneficiary” may continue to use the life expectancy method to calculate minimum annual distributions from an inherited IRA or other retirement account. Those individuals eligible to use this technique are: (i) surviving spouses; (ii) children of the account owner who have not reached majority; (iii) disabled individuals; (iv) individuals who are chronically ill; and (v) beneficiaries not more than 10 years younger than the deceased account owner. All but the surviving spouse category bear a closer look.

Child of the account owner who has not reached majority. People may assume the term “majority” as used in the Act means age 18. For purposes of the new rules, a child could reach the age of majority at age 26. Under current Internal Revenue Code and Regulations, a child may be treated as not having reached the age of majority until age 26 if they have not completed a “specified course of education.” Thus, if both conditions are met, a surviving child of the deceased account owner may use the life expectancy method of calculating distributions until age 26. However, this may change with future regulations. Nevertheless, when the child reaches majority, he must then switch to the new 10 year distribution rule with regard to any funds remaining in the inherited account. This category excludes grandchildren of the deceased account owner.

Furthermore, a child who is disabled as defined in the Internal Revenue Code when he reaches majority may continue thereafter to use the life expectancy method of calculating minimum annual distributions so long as he continues to be disabled.

Disabled persons. Not all disabled persons may use the life expectancy method of calculating minimum annual distributions from an inherited retirement account. Under the Act, an individual is considered to be disabled if she is unable to engage in any substantial gainful activity by reason of a medically determinable physical or mental impairment which can be expected to result in death or to be of long continued and indefinite duration. (This is the same definition used to determine whether a pre-age 59½ withdrawal from an IRA will be subject to the 10% early withdrawal penalty.) The beneficiary must provide proof of her disability. If the beneficiary does not meet, or no longer meets this definition of “disabled,” she must use the 10 year distribution period mandated by the Act.

The chronically ill. Under the Act, a “chronically ill individual” is one who has been certified by a licensed health care practitioner as: (i) being unable to perform at least two activities of daily living for a period that is indefinite and reasonably expected to be lengthy in nature due to a loss of functional capacity , (ii) having a level of disability that is similar to the level of that described in clause (i) above, or (iii) requiring substantial supervision to protect the individual from threats to health and safety due to cognitive impairment. If the beneficiary is deemed to be chronically ill, he may use the life expectancy method to calculate minimum annual distributions from an inherited retirement account. This definition is stricter than the definition found in a typical long term care insurance policy, which will require that an individual be unable to perform activities of daily living for at least 90 days to be deemed “chronically ill.”

Individuals not more than 10 years younger than the deceased account owner. This category of eligible designated beneficiary includes surviving siblings, a domestic partner, or friends of the deceased account owner if they are not more than 10 years younger than the deceased. Any beneficiary falling within this category may use the life expectancy method of calculating required annual distributions from an inherited retirement account.

For any designated beneficiary who is not an eligible designated beneficiary under the Act, he or she must withdraw the entire balance of an inherited retirement account within 10 years after the year of the death of the account owner if the death occurs after December 31, 2019.

The SECURE Act brought significant changes to an already complex area tax law and will have an impact on many financial and estate plans. As with any tax law change, one should review their financial or estate plan to determine how these changes may affect them.

Do you need help understanding the impact the SECURE Act has on your current planning, or need help determining how best to adapt your financial or estate plan to the new law? Give me a call, I can help.