CRPC Required Minimum Distributions and Beneficiary Planning 5 — Questions and Answers
Question 1: A surviving spouse inherits an IRA and elects spousal rollover treatment. What is the earliest the spouse must begin taking RMDs from the rolled-over account?
- December 31 of the year the original owner would have turned 73
- April 1 following the year the surviving spouse turns 73 (Correct answer)
- December 31 of the year following the original owner's death
- Immediately upon completing the rollover
Correct answer: April 1 following the year the surviving spouse turns 73
When a surviving spouse rolls over an inherited IRA into their own IRA, RMDs are governed by the spouse's own age—beginning April 1 following the year they turn 73 under SECURE 2.0.
Question 2: Which of the following describes the 'separate account' rule relevant to multiple IRA beneficiaries?
- Each beneficiary must create separate accounts by December 31 of the year following the IRA owner's death to use their own life expectancy (Correct answer)
- Separate accounts must be established within 30 days of death to qualify
- The rule requires the executor to split the account before any distributions are made
- Separate account treatment applies automatically regardless of when accounts are divided
Correct answer: Each beneficiary must create separate accounts by December 31 of the year following the IRA owner's death to use their own life expectancy
Beneficiaries who establish separate inherited IRA accounts by December 31 of the year after the owner's death may each use their own life expectancy for RMD calculations.
Question 3: An IRA owner names a see-through trust as beneficiary. What is the maximum distribution period available to the trust beneficiaries under SECURE Act rules if the trust's oldest beneficiary is a 50-year-old adult child?
- Life expectancy of the oldest trust beneficiary using Single Life Table
- 10 years from the IRA owner's death (Correct answer)
- 5 years from the IRA owner's death
- Life expectancy of the youngest trust beneficiary
Correct answer: 10 years from the IRA owner's death
Adult children named as trust beneficiaries are non-eligible designated beneficiaries, so the 10-year rule applies rather than the life expectancy stretch.
Question 4: What is the 'required beginning date' (RBD) for a non-5%-owner participant in an employer-sponsored qualified plan who is still employed?
- April 1 following the year they turn 73
- April 1 following the later of the year they turn 73 or the year they retire (Correct answer)
- December 31 of the year they turn 73
- April 1 following the year they turn 70½
Correct answer: April 1 following the later of the year they turn 73 or the year they retire
Non-5%-owner active employees may defer plan RMDs until April 1 following the later of age 73 or the year of actual retirement.
Question 5: A client converts a traditional IRA to a Roth IRA in 2025. How does this affect the current year's RMD obligation on the traditional IRA?
- The RMD must be taken before the conversion; it cannot be rolled over or converted (Correct answer)
- The RMD is automatically waived in a conversion year
- The RMD may be included in the converted amount and moves tax-free into the Roth
- The conversion eliminates future RMDs retroactively for the current year
Correct answer: The RMD must be taken before the conversion; it cannot be rolled over or converted
An RMD cannot be converted to a Roth IRA; the owner must first satisfy the traditional IRA RMD for the year, and only remaining funds may be converted.
Question 6: Which strategy allows a surviving spouse who is younger than the deceased IRA owner to delay RMDs as long as possible after inheriting the IRA?
- Elect inherited IRA treatment and postpone distributions until the deceased owner would have turned 73 (Correct answer)
- Immediately roll over the inherited IRA into their own IRA
- Disclaim the IRA so it passes to a contingent beneficiary
- Convert the inherited IRA to a Roth IRA to avoid RMDs entirely
Correct answer: Elect inherited IRA treatment and postpone distributions until the deceased owner would have turned 73
A younger surviving spouse can elect inherited (not own) IRA treatment, which allows deferral of RMDs until the deceased owner would have reached their required beginning date—potentially delaying distributions further than a spousal rollover.
Question 7: Under the SECURE 2.0 Act, Roth accounts in employer-sponsored plans (e.g., Roth 401(k)) are now treated how with respect to lifetime RMDs?
- Roth 401(k) accounts are exempt from lifetime RMDs beginning in 2024, matching Roth IRA treatment (Correct answer)
- Roth 401(k) accounts remain subject to lifetime RMDs at age 73
- Roth 401(k) RMDs were eliminated only for participants born after 1960
- Roth 401(k) accounts must distribute 50% by age 73 and the remainder by age 80
Correct answer: Roth 401(k) accounts are exempt from lifetime RMDs beginning in 2024, matching Roth IRA treatment
SECURE 2.0 eliminated lifetime RMDs for Roth accounts in employer plans effective 2024, aligning them with Roth IRA rules.
CRPC Required Minimum Distributions and Beneficiary Planning 5
A surviving spouse inherits an IRA and elects spousal rollover treatment.
What is the earliest the spouse must begin taking RMDs from the rolled-over account?