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Posted

80 year old participant died this year. 86 year old husband/owner is beneificiary. I am reading conflicting information on future RMD's.

Page 6-22 of this link states if the life expectancy of the deceased participant is greater than the beneficiary, you use that divisor and reduce it by one each calendar year.

IRS RMD's

The 401(k) Answer Book (2011 edition) makes no mention of reducing the divisor by one each calendar year for a spousal beneficiary. It states as follows "If the participant has a designated beneficiary as of 9/30 of the calendar year following the calendar year of death, the the distribution period is based on the beneficiary's life expectancy using the ben. age as of his or her birthday in the calendar year following the calendar year of the part. death or, if longer, it is based on the participants remaining life expectancy. In subsequent years, the distribution period is reduced by one for each year after the calendar year in which life expectancy was originally determined. HOWEVER, if the spouse is the participants sole beneficiary, then the spouse's life expectancy is recalculated each year based on their birthday for the year in which a min. dist. is required. For this purpose, life expectancies are based on the single life table"

I may be over thinking this or misinterpreting but I'm thinking the former is accurate rather than the latter as I have found more than one discrepancy in my usage of the Wolters Kluwer's answer books.

Posted

They appear to say the same thing. The concept is that you will always determine the RMD based on the longer of the two life expectancies. The issue is that when performing that determination, the "Spouses" single life expectancy will be recalculated each year (and then compared to the participant's life expectacy in the year of death (reduced by one each subsequent).

For non-spouse, you're reducing both the participant and non-spouse, so you'll never have to compare again. For a spousal beneficiary, If the participant was younger ( and had a longer life expectancy), you'd start out using that one. In the future (through recalculation of the spouse), the spouse's life expectancy may become longer (so you'd begin to use the spouses).

It's just a different way of saying the same thing.

Good Luck!

CPC, QPA, QKA, TGPC, ERPA

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