spouse still working age 74 died March 2020 had 401(k) had not started RMDs

spouse age 74 was still working when died March 2020. He had 401(k) and had not started RMD’s. Wife born September 1949 age 71. Is RMD due by 12/31 this year? Does she have to take RMD for 2020 even though it was waived because of COVID? is RMD based on husband birthday or wife birthday?



There is no 2020 year of death RMD due to the waiver, and there would not have been a 2020 RMD even without the waiver since participant passed prior to RBD. But 2021 is a beneficiary RMD year for the surviving spouse and that RMD will have to be distributed before any rollover is done to her own IRA. Wife will have an IRA owners RMD due for 2022, but that will be lower than her 2021 beneficiary RMD from the 401k plan. There is no benefit for wife to do a direct rollover to an inherited IRA, it should be to her own IRA. The Secure Act has no effect on this situation, it is the same as prior to Secure.



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