Client has an Individual Retirement Annuity that pays him $12,000 annually. Client also has Individual Retirement Account invested in various mutual funds. Assume value of each IRA is $200,000. Can you aggregate the IRA annuity and the IRA account to determine total RMD for year? For instance, if the aggregate RMD is $20,000, can the annual distribution from the annuity be combined with $8,000 distribution from the IRA account to satisfy the $20,000?

Here is a copy of the First Q & A 1.408-8 see Bolded section. Since the Annuity is treated just the same as any other IRA for purposes of this section, then aggregation is permissable. And also see 1.408-8 Q & A 9

10.1 Q-1. Is an IRA subject to the distribution rules provided in section 401(a)(9) for qualified plans?
A-1. (a) Yes, an IRA is subject to the required minimum distribution rules provided in section 401(a)(9). In order to satisfy section 401(a)(9) for purposes of determining required minimum distributions for calendar years beginning on or after January 1, 2003, the rules of §§1.401(a)(9)-1 through 1.401(a)(9)-9 and 1.401(a)(9)-6T for defined contribution plans must be applied, except as otherwise provided in this section. For example, whether the 5-year rule or the life expectancy rule applies to distributions after death occurring before the IRA owner's required beginning date is determined in accordance with §1.401(a)(9)-3 and the rules of §1.401(a)(9)-4 apply for purposes of determining an IRA owner's designated beneficiary. Similarly, the amount of the minimum distribution required for each calendar year from an individual account is determined in accordance with §1.401(a)(9)-5. For purposes of this section, the term IRA means an individual retirement account or annuity described in section 408(a) or (b). The IRA owner is the individual for whom an IRA is originally established by contributions for the benefit of that individual and that individual's beneficiaries.(b) For purposes of applying the required minimum distribution rules in §§1.401(a)(9)-1 through 1.401(a)(9)-9 and 1.401(a)(9)-6T for qualified plans, the IRA trustee, custodian, or issuer is treated as the plan administrator, and the IRA owner is substituted for the employee.[192]

© See A-14 and A-15 of §1.408A-6 for rules under section 401(a)(9) that apply to a Roth IRA.

10.9 Q-9. Is the required minimum distribution from one IRA of an owner permitted to be distributed from another IRA in order to satisfy section 401(a)(9)?
A-9. Yes, the required minimum distribution must be calculated separately for each IRA. The separately calculated amounts may then be totaled and the total distribution taken from any one or more of the individual's IRAs under the rules set forth in this A-9.[207] Generally, only amounts in IRAs that an individual holds as the IRA owner may be aggregated. However, amounts in IRAs that an individual holds as a beneficiary of the same decedent and which are being distributed under the life expectancy rule in section 401(a)(9)(B)(iii) or (iv) may be aggregated, but such amounts may not be aggregated with amounts held in IRAs that the individual holds as the IRA owner or as the beneficiary of another decedent.[208] Distributions from section 403(b) contracts or accounts will not satisfy the distribution requirements from IRAs, nor will distributions from IRAs satisfy the distribution requirements from section 403(b) contracts or accounts.[209] Distributions from Roth IRAs (defined in section 408A) will not satisfy the distribution requirements applicable to IRAs or section 403(b) accounts or contracts and distributions from IRAs or section 403(b) contracts or accounts will not satisfy the distribution requirements from Roth IRAs.[210]

Many thanks, JVED.

As an addendum, Q & A 1 above includes the Temp Regs for the distribution of Annuities as Part of the IRA RMD rules unless otherwise stated in the IRA Regs. Being the case that the annuity contract has been annuitized, it in effect has been separately calculated and separately satifies the regulations.

The added IRA account with Mutual Funds etc. in essence is being satisfied separately by the additional $8,000 and an overage from the annuity dist.. I'm assuming that since both accounts are initially valued the same that the $12,000 from the annuity is more than the calculated RMD for the annuity. In future years, the valuation of the annuity may be an issue. The regulations do not address this issue clearly. ( at least not to my non-actuarial self).

Therefore I agree with the answer you received on the 72(t).net site. (I visit there on a regular basis.)

Regards