RMD's

[kwalified]

Owner and his wife, both employed, they have been taking RMD's. She dies this year at age 81. He is beneficiary, currently age 87. Law states you should use single life table in 1.401(a)(9) using beneficiary age instead of Joint Life for her current year RMD. For future plan years how should RMD's be calculated for beneficiary? How should his RMD be calculated in current year? using Joint Life Table?

[Belgarath]

Let's see...if I'm thinking straight this afternoon (a dubious proposition at best)

With regard to the RMD for the deceased, it isn't a "post death" distribution in the year of death. The RMD for the year of death is determined under, in this case, the uniform lifetime table. For the applicable distribution period in subsequent years, see 1.401(a)(9)-5, Q&A-5(a).

For the beneficiary's RMD's, from the beneficiary's own account, since they are still lifetime distributions, again, you'd continue use the uniform lifetime table.

[kwalified]

Thanks for your response.

So she passed away this year age 81, you would use 17.9 factor under the Uniform Life Table and subsequent RMD's to her beneficiary would be under Single Life using his age. She passed in March 2012. Plan year ended July 2012.

Question: If he rolled over her benefits to his account would you still use the 2 tables and just have to account for the balances separately?

[masteff]

Law states you should use single life table in 1.401(a)(9) using beneficiary age instead of Joint Life for her current year RMD.

You're not quoting the rule correctly. From 1.409(a)-5 Q&A-5:

"(1) If the employee has a designated beneficiary as of the date determined under A-4 of § 1.401(a)(9)-4, the longer of—

(i) The remaining life expectancy of the employee's designated beneficiary determined in accordance with paragraph ©(1) or (2) of this A-5; and

(ii) The remaining life expectancy of the employee determined in accordance with paragraph ©(3) of this A-5;"

See also page 33 of IRS Pub 590 http://www.irs.gov/pub/irs-pdf/p590.pdf