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Level 3
posted Nov 24, 2022 10:50:10 PM

Calculating RMDs for traditional IRAs inherited after 2019

I inherited a traditional IRA from my dad in 2020 and it falls under the 10-year rule.  If I calculate the RMDs on current life expectancy tables and make 9 years of RMD withdrawals it results in a large "Balloon" distribution in year 10?  I've been advised by some helpful people on this board that penalties are waived for failing to make RMDs for 2021 & 2022.   As of today, its my understanding that the IRS has not yet finalized any decisions on RMD requirements for 2023.  So my question is, "Has anyone seen or heard any discussion about changes in the RMD calculation for these short window inherited IRAs?"  Thanks for any help you can provide. 

0 23 1656
5 Best answers
Level 15
Nov 25, 2022 5:25:52 AM

@shydig --  you may want to contemplate distributions LARGER than RMD so there isn't a balloon in the 10th year.  That 10th year balloon could put you in a higher tax bracket, so best to try and smooth out the distributions, but it is depedent on your specific income situation. 

 

a simple strategy suggested by others on these boards would be to distribute 1/9 of the 12/31/21 balance this year, 1/8 of the 12/31/22 balance in 2023, 1/7 of the 12.31.23 balance in 2024, etc.  That way there is no balloon in year 10 and you've smoothed out the distributions over time. 

 

However, that is just a simple approach, this can get more complicated if you are on Medicare or are going to go on Medicare during these 10 years - because there is something called "IRMAA" which adds to your medicare premium, but is really a tax in disguide, based on your AGI, which of course is now going to be higher because of the distributions from the inherited IRA.  Dependent on your income you can develop strategies to minimize this phanton tax.  

 

this is a good article that explains IRMAA

 

https://thefinancebuff.com/medicare-irmaa-income-brackets.html

 

also, the current set of tax brackets are set to revert to the 2017 tax brackets in 2026, unless Congress adjusts them.  That means taxes will be higher in 2026, so another strategy is to front load the distributions during 2022-2025 to take advantage of lower tax brackets.  

 

Depending on your income level, this gets very complicated and is not for the faint of heart! 

 

ps RMD is an abbreviation for Required MINIMUM distribution, not Required MAXIMUM distribution 😀

 

 

Level 15
Nov 25, 2022 4:59:59 PM

The notice says the Ruling does not apply before 2023.

So if you decide to skip the 2022 RMD, IRS will let you get away with that.

 

 

The Build Back Better is dead along with its restrictions on Roth Conversion.

No one can predict what Congress will do in the future.

 

@shydig 

 

 

Level 15
Nov 26, 2022 9:17:13 AM

@shydig - here is a GREAT article on the 'time bomb' that awaits if you defer Roth Conversions.  for many, there is a 'sweet spot' to accelerate Roth Conversions during the years after you retire and before Social Security (age 70 at the outside) and RMDs (age 72) kick in.  

 

https://www.kiplinger.com/retirement/retirement-planning/605109/is-your-retirement-portfolio-a-tax-bomb

 

It is interesting that we have been conditions to 'defer, defer, defer' during our working years, but during the 'sweet spot' noted above, the mantra should really be 'accelerate, accelerate, accelerate'.  (and it is VERY painful to write these BIG checks to the IRS each quarter; I've been doing it the last 4 years to take advantage of the 'sweet spot').

 

Once SS and RMDs kick in, reducing income and staying out of higher tax brackets and higher IRMAA payments is literally impossible without giving the money away via QCDs. 

 

I've put a lot of time into this topic and one piece of advice: I wouldn't worry about whether Congress changes the rules again. (for example, even though the tax brackets are scheduled to revert to 2017 levels comes 2026, Congress could always extend the current brackets, so even That is even an unknown).   It's complicated enough to come up with a plan with the known rules. 

 

enjoy reading! 

 

 

Level 15
Nov 28, 2022 11:20:33 AM

"Since the taxpayer is required to take RMDs on the inherited IRA, does that have to take place prior to doing a Roth Conversion from the taxpayer's own IRA in any given year?  "

 

As we know, Inherited IRAs are maintained independently of Traditional IRAs.

The answer is NO.

 

@NCperson 

 

Level 15
Feb 10, 2024 5:52:32 AM

TurboTax is actually asking how much of the distribution is ineligible for rollover.  Because a distribution paid to a non-spouse beneficiary is never eligible for rollover, the correct answer it that it is all RMD.  However, TurboTax already treats a distribution paid to a non-spouse beneficiary as being ineligible for rollover, so the answer you provide to this unnecessary question is irrelevant (even in years where the penalty for not taking the RMD is not waived).

23 Replies
Level 15
Nov 25, 2022 5:15:38 AM

It's not clear what your concern is.  You can always take out more than the RMD.  The RMD is the minimum you must take in any given year.

Level 15
Nov 25, 2022 5:25:52 AM

@shydig --  you may want to contemplate distributions LARGER than RMD so there isn't a balloon in the 10th year.  That 10th year balloon could put you in a higher tax bracket, so best to try and smooth out the distributions, but it is depedent on your specific income situation. 

 

a simple strategy suggested by others on these boards would be to distribute 1/9 of the 12/31/21 balance this year, 1/8 of the 12/31/22 balance in 2023, 1/7 of the 12.31.23 balance in 2024, etc.  That way there is no balloon in year 10 and you've smoothed out the distributions over time. 

 

However, that is just a simple approach, this can get more complicated if you are on Medicare or are going to go on Medicare during these 10 years - because there is something called "IRMAA" which adds to your medicare premium, but is really a tax in disguide, based on your AGI, which of course is now going to be higher because of the distributions from the inherited IRA.  Dependent on your income you can develop strategies to minimize this phanton tax.  

 

this is a good article that explains IRMAA

 

https://thefinancebuff.com/medicare-irmaa-income-brackets.html

 

also, the current set of tax brackets are set to revert to the 2017 tax brackets in 2026, unless Congress adjusts them.  That means taxes will be higher in 2026, so another strategy is to front load the distributions during 2022-2025 to take advantage of lower tax brackets.  

 

Depending on your income level, this gets very complicated and is not for the faint of heart! 

 

ps RMD is an abbreviation for Required MINIMUM distribution, not Required MAXIMUM distribution 😀

 

 

Level 3
Nov 25, 2022 3:16:50 PM

Thanks for your help.  Thanks for timely advice on IRMAA as I am 62.  I'm working on a 10-year plan.  Historically, my strategy focused on tax deferral.   Today, I'm "blessed" with limited income so I'm shifting strategies to minimize long-term taxes.  The inherited IRA withdrawal is a mandate with 8 years remaining for me.  As of today, I still enjoy flexibility on how/when I realize that income. But any potential changes in the RMD rules are important to me.  The other major consideration driving my plan is Roth conversion.  Again, there is a lot of noise around the IRS changing rules on conversion.  If those rules are going to change, I don't want to miss the window of opportunity for conversion (or partial conversion).  If the IRS is waiving penalties for inherited IRA RMDs for 2022 I'm considering skipping that for 2022 and just realizing income from a partial Roth conversion.  Obviously, I'm trying to balance both streams to remain in a lower tax bracket.   Thanks for all of your help.                

Level 15
Nov 25, 2022 4:31:18 PM

This was all covered in detail on your previous thread from the other day, and I thought we answered your question.

You will have to take the RMDs in 2023 and following years since the owner died after the age of 72.

 

@shydig 

Level 15
Nov 25, 2022 4:59:59 PM

The notice says the Ruling does not apply before 2023.

So if you decide to skip the 2022 RMD, IRS will let you get away with that.

 

 

The Build Back Better is dead along with its restrictions on Roth Conversion.

No one can predict what Congress will do in the future.

 

@shydig 

 

 

Level 3
Nov 25, 2022 7:30:34 PM

Thanks again for your insights and patience.   Sorry to seem redundant.  Just trying to develop a 10-year plan without getting whipsawed by some known, upcoming change on RMDs and/or conversions.  Now I am at least comfortable with year one of my plan. 

Level 15
Nov 26, 2022 9:17:13 AM

@shydig - here is a GREAT article on the 'time bomb' that awaits if you defer Roth Conversions.  for many, there is a 'sweet spot' to accelerate Roth Conversions during the years after you retire and before Social Security (age 70 at the outside) and RMDs (age 72) kick in.  

 

https://www.kiplinger.com/retirement/retirement-planning/605109/is-your-retirement-portfolio-a-tax-bomb

 

It is interesting that we have been conditions to 'defer, defer, defer' during our working years, but during the 'sweet spot' noted above, the mantra should really be 'accelerate, accelerate, accelerate'.  (and it is VERY painful to write these BIG checks to the IRS each quarter; I've been doing it the last 4 years to take advantage of the 'sweet spot').

 

Once SS and RMDs kick in, reducing income and staying out of higher tax brackets and higher IRMAA payments is literally impossible without giving the money away via QCDs. 

 

I've put a lot of time into this topic and one piece of advice: I wouldn't worry about whether Congress changes the rules again. (for example, even though the tax brackets are scheduled to revert to 2017 levels comes 2026, Congress could always extend the current brackets, so even That is even an unknown).   It's complicated enough to come up with a plan with the known rules. 

 

enjoy reading! 

 

 

Level 3
Nov 26, 2022 7:26:40 PM

Many Thanks.  That is a great article.  I'm guessing lots of folks (without a tax advisor) aren't aware of the time bomb they will face with RMDs.  I am in the sweet spot.  The long-term tax advantages of a Roth conversion will be a priority in my plan.  I agree that it's complicated enough to come up with a plan under the known rules.  The only thing that is certain about the tax code is that Congress will continue to make changes.  With that in mind, I plan to accelerate my conversions.  Thanks again for some great insights.

Level 15
Nov 27, 2022 11:05:11 AM

@shydig - one small point for your plan...  RMDs must be satified before your can do Roth Conversions... 

Level 3
Nov 27, 2022 10:29:06 PM

Thanks again!  Good to know.  Need to look into that to see how it impacts me for 2022.  I may have to do the semi-required RMD on the inherited iRA this year too.  

Level 15
Nov 28, 2022 8:43:51 AM

You don't have to take  an RMD before a conversion if you are not going to take an RMD.

If you are 62 you don't have RMDs.

@shydig 

 

Level 15
Nov 28, 2022 9:15:32 AM

@fanfare -that is actually an intersting question and wonder your thoughts:

 

taxpayer is 62 and inherited an IRA from a parent who was subject to RMDs and passed in 2021.  

 

Since the taxpayer is required to take RMDs on the inherited IRA, does that have to take place prior to doing a Roth Conversion from the taxpayer's own IRA in any given year?  The taxpayer owns both IRAs..... one inherited and one his one. 

Level 15
Nov 28, 2022 11:20:33 AM

"Since the taxpayer is required to take RMDs on the inherited IRA, does that have to take place prior to doing a Roth Conversion from the taxpayer's own IRA in any given year?  "

 

As we know, Inherited IRAs are maintained independently of Traditional IRAs.

The answer is NO.

 

@NCperson 

 

Level 3
Nov 28, 2022 9:15:12 PM

@NCperson

@fanfare 

Thanks for digging deeper on this issue.  Very helpful.  Your help may keep me out of trouble this tax season.

 

Level 2
Feb 10, 2024 5:39:42 AM

Now a year plus later, can anyone with knowledge chime in on where the IRS has ended up on the issue of RMDs for non-spouse inherited IRA as pertaining to the 2023 tax year and beyond?

 

Specifically, for those like the OP and myself who have non-spouse inherited IRAs under the newer 10-year required draw-down period?

 

My deceased father was old enough to have begun taking RMDs on his IRA up until his death in 2020, where he took his final RMD. But for the 21 and 22 tax years,  I didn't do any formal RMDs for that account that I inherited because of the IRA's pending guidance.

 

But I did for the past two years start doing my own informal 10-year plan of distributions/withdrawals each year in order to avoid the balloon tax debt problem at the end of my 10 year drawdown period.

 

TurboTax is asking me this year how much of my 2023 distribution was an RMD -- all, none or part. I'm sure I withdrew more in 2023 than whatever formula RMD applies. But I don't know how to calculate what my actual RMD would be, and whether it's based on MY age when I inherited the IRA, or what my father's age is/was???

 

Level 15
Feb 10, 2024 5:45:23 AM

For beneficiaries required under the proposed regulations to take RMDs under the 10-year rule, the IRS has similarly waived the penalty for not taking the RMD in 2023.

Level 2
Feb 10, 2024 5:47:54 AM

Wow! That's good news... So why then is TT bugging me about how much of my 2023 inherited IRA distribution was an RMD vs how much wasn't???

Level 15
Feb 10, 2024 5:52:32 AM

TurboTax is actually asking how much of the distribution is ineligible for rollover.  Because a distribution paid to a non-spouse beneficiary is never eligible for rollover, the correct answer it that it is all RMD.  However, TurboTax already treats a distribution paid to a non-spouse beneficiary as being ineligible for rollover, so the answer you provide to this unnecessary question is irrelevant (even in years where the penalty for not taking the RMD is not waived).

Level 2
Feb 10, 2024 5:53:29 AM

And how about this part pertaining to inherited non-spouse IRAs on the 10-year drawdown plan:

 

"But I don't know how to calculate what my actual RMD would be [ for future years where there might actually be a penalty for failing to do the required RMD], and whether it's based on MY age when I inherited the IRA, or what my father's age is/was???"

Level 15
Feb 10, 2024 6:04:56 AM

Assuming that your father was the original owner of the traditional IRA making you the original designated beneficiary, your RMDs are calculated by dividing the previous year end value in the inherited IRA by your life expectancy factor.  Your life expectancy factor is your life expectancy from the Single Life Expectancy table for your age in the year following the year your father died, reduced by 1 each subsequent year.  The table is in Appendix B of the 2022 or later version of IRS Pub 590-B.  (Don't use the table from earlier versions of that publication.  The IRS updated the life-expectancy the tables.)

 

https://www.irs.gov/pub/irs-pdf/p590b.pdf

 

Because the account must be fully depleted by the end of year 2030 in this case, you might want to take distributions that are larger than the RMD to spread the taxable income out more evenly over the years.

Level 2
Feb 10, 2024 6:34:56 AM

Correct re your question, yes, my father was the original IRA owner and thus I as his beneficiary/inheritor am the original owner of what's become my inherited IRA.

 

Just to clarify re your comment above -- "RMDs are calculated by dividing the previous year end value"

 

Previous year end value meaning for the year that he died? Or previous year end value for whenever I'm doing the annual RMD calculation now, and in future years?

 

Level 2
Feb 10, 2024 6:36:48 AM

PS - Thanks so much for all the very helpful / useful info above!  😊

Level 15
Feb 10, 2024 7:29:10 AM

For a 2024 RMD, divide the 2023 year-end value by the factor.