Inherited IRAs and Required Minimum Distributions – Why Waivers Matter

The Setting Every Community Up for Retirement Enhancement (SECURE) Act 1.0, enacted in December 2019, introduced significant changes to the rules governing Required Minimum Distributions (RMDs) for inherited Individual Retirement Accounts (IRAs). These changes, while intended to simplify the distribution process, have led to considerable confusion among beneficiaries regarding their obligations and tax implications. In particular, the legislation introduced a new 10-year rule for distributions, replacing the previous life expectancy method for most beneficiaries. This article delves into the intricacies of these changes, the confusion surrounding RMDs, and the importance of understanding waivers and their tax implications.

The SECURE Act and the 10-Year Rule

Prior to the SECURE Act, non-spouse beneficiaries of inherited IRAs could “stretch” distributions over their life expectancy, allowing for extended tax deferral. However, the SECURE Act mandated that most beneficiaries must fully distribute the inherited IRA within 10 years of the original owner’s death. This 10-year rule is clear in its requirement that the entire account be emptied by the end of the decade, but ambiguity arose regarding whether annual RMDs were still required within that period.  For more detailed guidance on inherited IRA RMD rules post the SECURE 2.0 Act, check out our blog post “You’ve Inherited an IRA—Now What Do You Do With It?”.

The Confusion Over Annual Required Minimum Distributions

The confusion centers on whether Congress intended for beneficiaries to continue taking annual RMDs, or if beneficiaries could wait until the end of the 10-year period to fully distribute the account. The IRS initially provided little guidance on this matter, leading to uncertainty and potential penalties for non-compliance.

In response, the IRS waived the excise tax penalty for missed RMDs for the years 2021, 2022, 2023, and again in 2024. This waiver means beneficiaries would not be penalized for failing to take annual distributions during these years. However, this waiver does not equate to a waiver of the RMD requirement itself; it simply postpones the penalty.

Differentiating Between Waiver of Excise Tax and RMDs

Understanding the distinction between the waiver of the excise tax and a waiver of the RMD requirement is crucial. The waiver of the excise tax penalty means that while beneficiaries are not penalized for missing annual distributions, they are still required to fully distribute the inherited IRA by the end of the 10th year. On the other hand, a waiver of the RMD requirement would imply that annual distributions are not mandatory, effectively extending the time to distribute the account.

The Tax Implications of Distribution Timing

For beneficiaries, especially those with larger inherited IRAs, the timing of distributions is a critical tax consideration. Compressing distributions into a shorter period, such as six years instead of 10, can have significant tax implications, potentially pushing the beneficiary into higher tax brackets.

Factors to Consider for Optimal Distribution Strategy

1. Current Income and Marginal Tax Bracket: Your current income level and marginal tax rate are fundamental factors. Taking distributions when your income is lower can help minimize the tax impact. For instance, if you are currently in a lower tax bracket, it may be advantageous to take larger distributions now rather than in future years when your income might be higher.
2. Eligibility to Contribute to Retirement Accounts: If you are eligible to contribute to retirement accounts such as a 401(k) or IRA, you might offset the tax impact of the inherited IRA distributions by increasing contributions to these accounts. This strategy can help reduce your taxable income and provide additional tax-deferred growth opportunities.
3. Future Income Expectations: Anticipating changes in your income over the next 5-10 years is crucial. If you expect your income to increase, it may be beneficial to take larger distributions from the inherited IRA now while your tax rate is lower or, as in the example above, you may do Roth contributions through your 401k or IRA as opposed to pre-tax contributions. Conversely, if you expect your income to decrease, deferring distributions could be advantageous.

Crafting a Distribution Strategy

When planning your distribution strategy, it is essential to consider your overall financial situation and long-term goals. Here are some scenarios to consider:

• Early-Career Individuals: If you are in the early stages of your career—which often means a lower income—it might be wise to take larger distributions now. Additionally, contributing to your retirement accounts can help offset some of the tax liabilities.
• Mid-Career Individuals: If you are mid-career and expect your income to rise, consider balancing distributions to avoid higher tax brackets. Splitting distributions over several years can help manage your tax burden more effectively.
• Near-Retirement or Retired Individuals: If you are nearing retirement or already retired, your income may be lower, providing an opportunity to take distributions from your inherited IRA at a reduced tax rate. For those already retired, you might consider taking all your retirement income from the inherited IRA instead of from your own 401(k) or IRA. This strategy can help manage your tax bracket more effectively and influence your investment decisions. By prioritizing distributions from the inherited IRA, you might preserve your own retirement accounts for future tax-deferred growth or for strategic withdrawals in later years. Careful planning is essential to avoid inadvertently pushing yourself into a higher tax bracket with large distributions. For more insights on optimizing your income in retirement, read our blog post “Tax Planning For Retirees: Strategies For Optimizing Your Income.“

Conclusion

The SECURE Act 1.0 introduced complexities in managing inherited IRAs, particularly concerning RMDs and distribution strategies. While the IRS has provided temporary relief through excise tax waivers, beneficiaries must still navigate the 10-year rule and plan their distributions carefully to minimize tax impact. By considering your current and future income, eligibility for retirement account contributions, and overall financial goals, you can develop an optimal strategy for managing inherited IRA distributions. Careful planning is essential to ensure that you maximize the benefits of your inherited IRA while minimizing unnecessary tax burdens.