IRA Digital Reference Manual - November 2024 - 265

Chapter 10 - Death Distributions
Spouse Beneficiary Can Elect to be Treated as Deceased Spouse for RMDs
Beginning for deceased IRA owners who would have reached their RMD age in 2024
or later, a surviving spouse beneficiary can elect to be treated as the deceased spouse for
purposes of the death RMD rules. If the election is made, death RMDs for the surviving
spouse would begin when the deceased IRA owner would have reached their RMD age. If
the IRA owner died on or after their RBD, this treatment is not necessarily automatic (i.e.,
the terms of the IRA document can dictate whether the election is made by default (i.e.,
automatic) or if the surviving spouse must choose it). Note that because IRA documents
are not yet required to be updated for these changes, a spouse who currently wants this
treatment would likely have to choose it. [Prop. Reg. §1.401(a)(9)-5(g)(3)(ii)]
For a death on or after the RBD, if this treatment applies, the surviving spouse will
calculate death RMDs using the greater (longer) of the surviving spouse's Uniform
Lifetime Table factor (not the Single Life Expectancy Table) or the decedent's remaining
life expectancy. The surviving spouse must be the sole IRA beneficiary, or if there are
multiple IRA beneficiaries, the spouse must be the sole beneficiary if separate accounts are
timely established by December 31 of the year after the IRA owner's death..
The surviving spouse can instead rollover, transfer, or elect to treat the IRA as their
own IRA and then be subject to the lifetime RMD rules (not the death RMD rules).
Successor Beneficiary
If the original Traditional IRA owner died on or after their required beginning date
(RBD) and died after 2019, and the original beneficiary was an eligible designated
beneficiary (EDB) who elected to use the life expectancy rule and had named a successor
beneficiary, the successor beneficiary who inherits the IRA funds must distribute the
remaining IRA funds within ten years after the original beneficiary died. In addition, the
successor beneficiary must take death RMDs based on the original beneficiary's remaining
single life expectancy (SLE) during the ten-year period. [Reg. §1.401(a)(9)-5(d)(1) and
(e)(3)]
✓Example: Rob died in 2023 at age 78 (after his RBD) and named his younger sister Kate, age
73 in 2023, as his Traditional IRA beneficiary. Kate (an EDB) chose the SLE option and began
taking death RMDs using her SLE starting in 2024 (the year after Rob's death). Kate dies in
2026 and her adult daughter Ann is the successor beneficiary. Ann is subject to the 10-year rule
and must deplete the IRA by December 31, 2036 (i.e., 10 years after Kate's death in 2026).
However, annual RMDs are required during this 10-year period because Rob SLE payments
had begun. The annual RMDs to Ann (the successor beneficiary) are based on Kate's remaining
SLE for the first 9 years after Kate's death (i.e., 2027 through 2035), with the remaining IRA
balance depleted by December 31, 2036.
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IRA Digital Reference Manual - November 2024

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