00hskrgrl Posted Thursday at 06:34 PM Posted Thursday at 06:34 PM Has anyone seen an expanded Uniform Lifetime Table that lists ages less than 70? Per the SECURE 2.0 changes, spousal beneficiaries can now elect to use the ULT factors instead of the SLA factors when they inherit a qualified retirement plan account. Under the final regulations, it appears that a spousal beneficiary must still begin RMDs as of the December 31st of the year in which the participant would have reach RMD age, if she has not moved her balance to an IRA. (Derrin Watson has a good explanation here: https://ferenczylaw.com/flashpoint-the-final-rmd-regulations-the-high-points/) For example, a participant born in 1953 dies in 2021. His spouse, born in 1957, does not move the balance out of the plan until 2026. In 2026, the participant would have been 73, so an RMD must be distributed prior to rolling the balance to an IRA. The spouse is only age 69, and she elects to use the more favorable ULT factors. I'm having a difficult time finding a ULT table based on the 2022 updates that lists ages less than 70 (most start at 72, but did find a few starting at age 70).
C. B. Zeller Posted 10 hours ago Posted 10 hours ago If you're seeing a ULT that starts at 70, it's outdated - the ULT is found in the regulations at sec. 1.401(a)(9)-9(c) and it starts at 72. The rule saying that a surviving spouse can use the ULT at their own age to determine the RMD is not actually in the final regulations yet, it's only contained in the proposed regulations from 2024. Consequently the expanded ULT is also only found in the proposed regulations at this point. You can find it here: https://www.federalregister.gov/d/2024-14543/p-115 00hskrgrl 1 Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance. Corey B. Zeller, MSEA, CPC, QPA, QKA Preferred Pension Planning Corp.corey@pppc.co
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