SECURE Act regs and minor beneficiary

Minor child of IRA owner inherits an IRA in 2020 at age 12 from an IRA owner who died pre RBD. The next year the minor begins life expectancy distributions that continue until 2029 when he turns 21. In 2030 we start the 10 year period that requires the entire IRA be distributed by the end of 2039. Are there any RMDs during the 10 year period? It is a pre RBD death which would seem to mean that there isn’t, but a minor has started life expectancy payments so maybe they need to continue during the 10 years? Is this addressed in the regs?



The minor ceases to be an EDB at the end of the year they reach 21. The 10 year rule then kicks in, but since the parent passed prior to RBD (and the vast majority of decedents with minor beneficiaries will pass prior to RBD), the LE RMDs no longer apply during the 10 year rule period.  In those cases where the parent passed post RBD, the LE RMDs would then continue throughout years 1-9 of the 10 year rule.
P 47 of the proposed Regs provides an example of a minor beneficiary having to continue LE RMDs after reaching 21, but this example was for a parent death post RBD. There is no overt statement that addresses death prior to RBD with respect to minor EDBs, and that suggests that the LE RMDs cease at 21 for those children.



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