Chapter 1: The Minimum Distribution Rules
53
See-through trust
¶ 1.5.03 (D)
¶ 1.5.04 (D)
Participant’s estate; a non-
see-through trust; any
nonindividual beneficiary.
¶ 1.5.03 (E); 5-year rule
applies
( ¶ 1.5.06 ) ¶ 1.5.04 (E); life expectancy
of participant
( ¶ 1.5.08 )Multiple beneficiaries
¶ 1.5.03 (F)
¶ 1.5.04 (F)
1.5.03
Road Map, cont.: RMDs in case of death BEFORE the RBD
To determine required distributions for retirement benefits of a participant who died
before
his
RBD, first complete the steps at
¶ 1.5.02 .Then read this
¶ 1.5.03 .First read the general
comments and caveats, and paragraph A. Then read the particular paragraph (B–F) that describes
the beneficiary. See
¶ 1.5.02 ,Step 3, for explanation of the RBD.
A.
RMD for year of death (regardless of who is beneficiary).
Because the participant died
before his RBD, there is no RMD for the year of his death. See
¶ 1.4.07 (C). Required
distributions will begin, at the earliest, the year
after
the year of the participant’s death.
B.
Surviving spouse is sole beneficiary.
If the participant died before his RBD, leaving his
benefits to his surviving spouse as sole beneficiary, the ADP is the surviving spouse’s life
expectancy, unless the 5-year rule applies. Reg.
§ 1.401(a)(9)-3 ,A-1(a). See
¶ 1.5.07for
how to determine whether the 5-year rule applies; see
¶ 1.5.06for how to calculate
distributions under the 5-year rule. See
¶ 1.6.02for meaning of “spouse is sole beneficiary.”
Se
e ¶ 1.6.03for how to calculate RMDs based on the spouse’s life expectancy. Se
e ¶ 1.6.04for when distributions to the spouse must commence (Required Commencement Date). See
¶ 1.5.12and
¶ 1.6.05for what happens if the spouse, having survived the participant, dies
before
that Required Commencement Date. See
¶ 1.5.12an
d ¶ 1.6.03 (E) for what happens
if the spouse, having survived the participant and lived
beyond
her Required
Commencement Date, dies before having withdrawn all of the benefits. See ¶ 3.2 for the
surviving spouse’s ability to roll over the inherited benefits to another retirement plan; see
¶ 1.6.03 (A), (B), for RMD effects of such a rollover.
General Comments and Caveats
Post-death RMDs from a
Roth IRA
are always determined using rules in this
¶ 1.5.03(never ¶
1.5.04 ). Reg.
§ 1.408A-6 ,A-14(b).
In
all
cases, see ¶
1.5.10for the ability of the plan to require faster distribution of the
benefits than the RMD rules would require.
See
¶ 3.2regarding the ability of the participant’s surviving spouse to roll benefits over
to her own IRA (or elect to treat an inherited IRA as her own); such a rollover or election would
change the RMD rules applicable to the rolled over benefits; see ¶
1.6.03 (A), (B), for RMD
effects.