No Beneficiary Named

Account Owner’s Required Beginning Date

The IRA Account Owner’s Required Beginning Date, or RBD, is April 1 of the calendar year following the calendar year in which the Account Owner attains their Applicable Required Minimum Distribution (RMD) Age. The Account Owner’s applicable RMD age differs depending on when the Account Owner was born, which is reflected in the table below.

Source:
Internal Revenue Code §401(a)(9)(C)(i)

Minor Child of Deceased Account Owner

For purposes of determining required minimum distributions from an inherited IRA, a minor child is a child, stepchild, adopted child, and eligible foster child of the deceased Account Owner and who is under age 21 as of the date of the Account Owner’s death. Also, an “eligible foster child” means an individual who is placed with the taxpayer by an authorized placement agency or by judgment, decree, or other order of any court of competent jurisdiction. Minor grandchildren, nieces, nephews, or any other minors generally do not qualify as “a minor child of the deceased Account Owner.”

Sources:
Treas. Reg. §§1.401(a)(9)-4(e)(1)(ii) and 1.401(a)(9)-4(e)(3)

Spousal Rollover

For purposes of determining required minimum distributions from an inherited IRA, the surviving spouse of the deceased Account Owner has an option that is not available to non-spouse beneficiaries: a spousal rollover.

A spousal rollover is an election to treat the deceased Account Owner’s IRA as the surviving spouse’s IRA, an election that may be made at any time after the Account Owner’s death. With this election, the inherited IRA is redesignated as an IRA in the name of the spouse as IRA owner rather than as beneficiary. As the name implies, this option is unique to a surviving spouse beneficiary.

To elect a spousal rollover, the surviving spouse must be the sole primary beneficiary of the deceased Account Owner’s IRA – a determination that is made by September 30 of the year following the Account Owner’s death. Also, the surviving spouse must have an unlimited right to withdraw amounts from the IRA.

A spousal rollover may be a suitable option if the surviving spouse does not require distributions from the account for current living expenses and prefers to defer distributions (and resulting income tax consequences) for a longer period of time.

Sources:
Internal Revenue Code §408(d)(3) and Treas. Reg. §1.408-8

Person Under Age 18 with a Disability

For purposes of determining required minimum distributions from an inherited IRA, a person under age 18 is considered disabled if they have a medically determinable physical or mental impairment that results in marked and severe functional limitations and that can be expected to result in death or to be of long-continued and indefinite duration.

If a beneficiary is determined to be disabled by the Social Security Commissioner, they are deemed to be disabled for inherited IRA required distribution purposes.

Documentation proving the disability, such as a certification from a licensed health care practitioner, must be provided to the IRA custodian no later than October 31 of the calendar year following the calendar year of the deceased Account Owner’s death.

Source:
Treas. Reg. §1.401(a)(9)-4(e)(4)

Person Age 18 and Older with a Disability

For purposes of determining required minimum distributions from an inherited IRA, a person age 18 and older is considered disabled if they are unable to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or to be of long-continued and indefinite duration.

If a beneficiary is determined to be disabled by the Social Security Commissioner, they are deemed to be disabled for inherited IRA required distribution purposes.

Documentation proving the disability, such as a certification from a licensed health care practitioner, must be provided to the IRA custodian no later than October 31 of the calendar year following the calendar year of the deceased Account Owner’s death.

Source:
Treas. Reg. §1.401(a)(9)-4(e)(4)

Chronically Ill Person

For purposes of determining required minimum distributions from an inherited IRA, a chronically ill person is any individual certified by a licensed health care practitioner within the preceding 12 months as:

1. Being unable to perform (without substantial assistance from another individual) at least 2 activities of daily living for a period of at least 90 days due to a loss of functional capacity. The activities of daily living are eating, toileting, transferring, bathing, dressing, and continence.
OR
2. Requiring substantial supervision to protect such individual from threats to health and safety due to severe cognitive impairment.

Documentation proving the chronic illness, such as a certification from a licensed health care practitioner, must be provided to the IRA custodian no later than October 31 of the calendar year following the calendar year of the deceased Account Owner’s death.

Source:
Treas. Reg. §1.401(a)(9)-4(e)(5)