Reply To: Incorrect coding after 1035 on inherited non-qualified annuity with RMD

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#1981
DTASFAB
Participant

I will try again.

Schwab says: “Your annual distributions are spread over your single life expectancy, which is determined by your age in the calendar year following the year of death and reevaluated each year.”

Fidelity says: “[U]se your own age and the IRS Single Life Expectancy Table for calculating the first year RMD. For each year after, you would subtract one year from the initial life expectancy factor.”

IRS says: “Determine beneficiary’s age at year-end following year of owner’s death… Reduce beginning life expectancy by 1 for each subsequent year.”

Am I correct that Schwab is technically correct in their wording, but ONLY because of the possibility that Table I could potentially be revised from year to year? In other words, in my specific situation, the 2013 edition of Table I listed the life expectancy of a 34 year old to be 49.4 years. Therefore, by subtracting 1 for each subsequent year, my life expectancy is now 43.4 for the 2019 tax year.

HOWEVER, we have to keep in mind that Table I in 2019 is still the same as Table I in 2013. Hypothetically, if the 2019 Table I life expectancy for a 34 year old were arbitrarily increased to 49.8 (it wasn’t, but this is hypothetical), my 2019 RMD divisor would be 43.8 rather than 43.4? Is that the “reevaluation” Schwab is talking about? If this is the case, it’s extremely confusing, because it can lead people to believe they just go by Table I each year, regardless of the beneficiary’s age in the year following the year of the decedent’s death. Fidelity and the IRS site are much more straightforward in my opinion, but NONE of them clarify this rule completely free of ambiguity.