On November 7, 2019 the Internal Revenue Service (IRS) released proposed updates to the life expectancy and distribution period tables which provide the divisors used to calculate required minimum distributions (RMDs) from employer plans and traditional, simplified employee pension (SEP), and Savings Incentive Match Plan for Small Employees (SIMPLE) individual retirement accounts (IRAs) and for Roth IRA beneficiaries. The existing tables were released in 2002 and have been effective since 2003.
The RMD Rules
RMDs are a series of annual distributions that must begin during an IRA owner’s lifetime or upon his/her death. An IRA owner’s first distribution year is the year in which he/she reaches age 70½. Distributions over an IRA owner’s lifetime are calculated using a divisor from either the Uniform Lifetime Table or the Joint Life and Last Survivor Table. After an IRA owner’s death, distributions made to a beneficiary are calculated using a divisor from the Single Life Expectancy Table.
Effect of the Change
The proposed changes to the life expectancy and distribution period tables have been made in a proposed regulation format. The updated tables will reflect a longer life expectancy than provided in the current regulation and tables. Beginning after 2020 this will give IRA owners and beneficiaries the ability to distribute a slightly smaller RMD amount compared to prior years.
Effective Date of Updated Tables
The proposed life expectancy tables would be used for distribution calendar years beginning on or after January 1, 2021. For example, for an individual who attains age 70½ during 2020 the deadline to take his/her first RMD is April 1, 2021. However, because the RMD is for tax year 2020 the existing life expectancy table will be used to calculate the 2020 RMD. For RMDs applicable to years after 2020, the updated life expectancy tables would be used to calculate the RMD.
Anita will attain age 70 on March 15, 2021. Under the current regulation the divisor from the Uniform Lifetime Table that Anita would use to calculate her RMD for 2021 is 27.4. If the RMD is calculated using the updated Uniform Lifetime Table from the proposed regulation, a divisor of 29.1 years will be used, resulting in a lesser RMD amount.
Transition Rule for Beneficiaries
The proposed regulations include a transition rule that applies to beneficiary RMDs which are paid out over a distribution period from the Single Life Table. In other words, if an IRA owner passed/passes away prior to January 1, 2021 the transition rule would allow the beneficiary the benefit of going back to the year following the IRA owner’s year of death to determine his/her single life expectancy from the proposed Single Life Expectancy Table and subsequently reduce that life expectancy divisor by one for each year that has passed; as if the proposed Single Life Expectancy Table was in effect the year following the year of death.
Claude, age 85 died in 2016 leaving his daughter Joan, age 51, as the beneficiary of his IRA. Joan started taking death distributions under the single life expectancy provision beginning in 2017 based on her age that year (i.e., 52). Under the current regulation and Single Life Expectancy Table, the divisor that Joan used beginning in 2017 was 32.3. Under the single life expectancy provision, a nonspouse beneficiary reduces the applicable divisor by one each year (i.e., the reduction method) resulting in a divisor of 28.3 for 2021. If the RMD is calculated using the divisor from the proposed Single Life Expectancy Table, her distribution period would be reset beginning in 2017 using a divisor of 34.3, resulting in a divisor of 30.3 in 2021, therefor reducing the RMD amount.
Hearing and Comments
Before the proposed regulations are adopted as final regulations, the Treasury Department and the IRS is requesting comments. All comments will be available for public inspection and copying at www.regulations.gov upon request. Comments will be considered at a public hearing scheduled for January 23, 2020.
The existing Life Expectancy Tables were released in 2002. Life expectancies have increased since then, and the proposed Life Expectancy Tables reflect current life expectancies.Go here to learn more about training opportunities available to you, or call us at 1-800-552-9408.