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Q:My client’s four children are the beneficiaries of his IRA. They each split their share of the inherited IRA into separate inherited IRAs the year following the year he died ( he died last year and they split the account this year). There is some disagreement as to whether they must use the oldest beneficiary’s life expectancy to calculate their distributions for this year, of if they can use their own life expectancies? In fact, we are looking at two books, and one says the oldest beneficiary’s life expectancy must be used, and the other says each can use their own.

Can they use their own life expectancies? Or are they required to use the oldest beneficiary’s life expectancy?

A: Each beneficiary can use his/her own life expectancy to calculate his/her RMD amount for this year.

The confusion may have come about, because when the Final RMD regulations were issued, it required the life expectancy of the oldest beneficiary to be used in such cases (i.e. for the year of the split, when the split occurred in the year following the year of death). However the IRS subsequently issued regulations modifying that provision, by allowing each beneficiary to use their own life expectancy in the year of the split.

Cite TD 9130

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