RMD for participant who died in 2017

100% owner died in 2017 at age 90 - he was obviously in RMD status.  His two sons (who became 50-50 owners of the business) were/are 50-50 beneficiaries of Dad's account.  Dad's money is still in the plan (it's a pooled profit sharing only plan).

The change in the SECURE rules is throwing me off.  How do we determine the RMD factor for, say, 2025?  It looks like the date of birth for the oldest son has been used, but I'm not sure that's correct.

Thanks.

If the beneficiary is not the spouse, the RMD amount is determined using the greater of:

The designated beneficiary’s life expectancy in the year following the year of the participant’s death reduced by a factor of 1 for each subsequent year; or

The participant’s life expectancy at the time of death, reduced by a factor of one for each subsequent year.

For multiple beneficiaries use only the one with the shortest life expectancy. 

Use the single life table/uniform lifetime table

Thanks.  So we could use the eldest beneficiary's age in 2018 to determine the 2018 RMD, and then subtract one from the factor each year?

And, speaking of this [dead] guy, is he exempt from the new SECURE rules about paying out within 10 years?

If the participant died after his required beginning date but did not receive the RMD for the year in which he died, you will use the participants info to calculate that year. All subsequent years will be based on comparing the participant’s Single Life Table factor (-1) to the oldest beneficiary’s Single Life Table factor and choosing the greater life expectancy factor for the calculation.  Essentially, here, choosing the oldest son’s factor each year. The SECURE Act changed the rules for participants who died after December 31, 2019 by eliminating the lifetime payment option and the five-year method. My guess is that if it was started using the life expectancy method, it can continue that way, but I would suggest seeking more formal advice on this particular situation.

I'm not sure using the oldest son's date of birth would be correct because a portion of the fathers money would be son A and the other portion of the money would be son B. Each son would have their own lifetime factor. It's a minimum distribution so there's no penalty for overcalculating or taking more.