Life and Death Planning for Retirement Benefits

51 / 507

Chapter 1: The Minimum Distribution Rules 51
 The participant’s date of birth and date of death. You can skip the “birth date” part for a
Roth IRA, or if you know the participant was younger than age 70½ at death.
 The identity of the participant’s beneficiary(ies). For an individual beneficiary, you need
to know the beneficiary’s date of birth and whether the beneficiary is the surviving spouse
of the participant. If the beneficiary is a trust, you need to know whether the trust qualifies
as a see-through trust (see . See for how to determine who is the
participant’s “beneficiary.”
 The type of plan you are dealing with: traditional IRA, Roth IRA, QRP, or 403(b) plan (see
¶ 8.3).
Step 2: Gather specialized information you may need to compute the RMD in some cases:
 If the participant died on or after April 1 of the year after the year in which he reached age
70½, and the plan is a QRP or 403(b) plan, you need to know whether the participant had
retired prior to his death and whether (in the case of a QRP) he was a “5-percent owner”
with respect to that plan. See
 If the plan is a 403(b) plan, is there a “pre-1987” account balance in the plan? If so, see
this Road Map will not work for the pre-1987 balance.
 If the plan is a QRP, did the participant have a TEFRA 242(b) election in effect since 1983?
If so, see this Road Map will not work for these benefits.
Step 3: Determine whether the participant died before, on, or after the RBD. See f the
decedent died BEFORE his RBD, use to determine post-death RMDs. If the
decedent died AFTER his RBD, use Death on the RBD is treated as death after
the RBD. Reg. A-6(a).
 If the plan is a Roth IRA , the death is always before the RBD, because Roth IRAs
have no RBD. A).
 If the participant died before April 1 of the year following the year in which he
reached (or would have reached) age 70½ then he died BEFORE his RBD for all
plans. See C).
 If he died on or after that date, see for how to determine the RBD for each of
the decedent’s plans; the RBD is not always easy to determine in this case, because
different types of plans have different RBDs. The participant may have died before
his RBD under some of his retirement plans but after the RBD for other plans. For
the most confusing situations, see: qualified plan’s RBD is earlier than
statutory RBD; and C), new IRA created via rollover or transfer.
 Finally, even though a participant who turned age 70½ (or retired, whichever was
applicable) in 2009 did not have to take an RMD for 2009, April 1, 2010, will still