Thanks Alan. I really appreciate your reply. But I do still have a question regarding the year of death RMD. Below is my research on this but since I’ve never encountered this in real life, I have no clue as to whether it even matters. How would the IRS even know? Am I overthinking this?Treasury Regulation 1.401(a)(9)-5 is entitled “Required Minimum Distributions for Defined Contribution Plans.” Regulation 1.401(a)(9)-5 uses a question and answer (“Q” and “A”) format. Question Q-4 asks: “For required minimum distributions during an [IRA owner’s] lifetime, what is the applicable distribution period?” The answer (A-4) is set forth in two paragraphs.Paragraph A-4(a) states a “general rule” that “except as provided in paragraph (b) to this A-4, for all years, up to and including the distribution calendar year in which the [IRA owner] dies, the annual distribution period must be derived from the Uniform Lifetime Table.”The paragraph A-4(b) “exception” provides its own “general rule.” It states that if the “sole designated beneficiary” of the IRA is the IRA owner’s spouse, then “for purposes of determining required minimum distributions during the [IRA owner’s] lifetime, the [Joint Life Table] may be applied.However, paragraph A-4(b) then goes on to state the following caveat:               “The spouse is the sole designated beneficiary for purposes              of determining the applicable distribution period for a distribution              calendar year during the [IRA owner’s] lifetime only if the spouse              is the sole beneficiary of the [IRA owner’s] entire interest at all               times during the distribution calendar year.”In my opinion, the above reference to “the sole beneficiary of the [IRA owner’s] entire interest at all times during the distribution calendar year” is dispositive. Once a disclaimer has been made, the disclaimant ceases to be “the sole beneficiary of the [IRA owner’s] entire interest” for whatever remains of that “distribution calendar year.” And that also means for purposes of the year of death RMD the Uniform Lifetime Table must be used instead of the Joint Life Table [in this case]. Treasury Regulation 1.401(a)(9)-4 provides additional support for the conclusion that disclaimers deprive the disclaimant of the requisite “designated beneficiary” status. It is entitled “Determination of the Designated Beneficiary.” Its Q-4 asks: “When is the designated beneficiary determined?” The answer states that to be a “designated beneficiary,” a person must not only hold that position when the IRA owner dies, but must continue to maintain it until September 30th of the year following the year of the owner’s death; and that: “Accordingly, if a person disclaims entitlement…pursuant to adisclaimer that satisfies Section 2518 by that September 30,thereby allowing other beneficiaries to receive the benefit inlieu of that person, the disclaiming person is not taken intoaccount in determining the [IRA owner’s] designated beneficiary.” It can be argued that both the question (Q-4) and answer (A-4) to Regulation 1.401(a)(9)-5 are expressly addressed only to the period “during the [IRA owner’s] lifetime.” But this interpretation is belied not only by the Q-4 and A-4 references to the full “distribution calendar year,” but also by the fact that Q-5 and A-5 (which immediately follow) specifically refer to determining the RMD after the owner’s death and define this to mean “the distribution calendar year after the distribution calendar year containing the [owner’s] death.” The clear implication of this juxtaposition is that Q-4 and A-4 do embrace the entire year-of-death calendar year.Likewise, it can be claimed that Regulation 1.401(a)(9)-4 has no bearing and only applies to the determination of beneficiaries’ RMDs beginning in the year after the owner has died; but even if this is so, the IRS’ view of the disqualifying impact of a disclaimer is made clear by that Regulation.  

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• When IRS Regs are published, the authors intend to address various situations not clear from the tax code. When the Regs also fail to clarify certain situations, IRS Pubs sometimes cut through the complexity. This is one of those situations where the following quote from Pub 590 B is clear. Note that if the IRA owner had not passed, there would be no disclaimer.
• “Table II (Joint Life and Last Survivor Expectancy). Use Table II if you are the IRA owner and your spouse is both your sole designated beneficiary and more than 10 years younger than you. Note. Use this table in the year of the owner’s death if the owner died after the required beginning date and this is the table that would have been used had he or she not died.”

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