Life Expectancy Tables and Required Minimum Distributions
By Marvin Rotenberg, IRA Technical Expert
IRS regulations governing required minimum distributions (RMDs) from IRAs and employer-sponsored retirement plans were in proposed form only from 1987-2000. Sweeping changes to these proposed regulations in 2001 led to the issuance of long-awaited final regulations in 2002, dramatically altering the way owners and beneficiaries of these accounts and plans calculate the distributions they are mandated to take from them.
The correct age to reference in any of the tables corresponds to the age of the IRA owner, plan participant or beneficiary as of December 31 of the year in question. For individuals taking their first distribution due to attainment of age 70 ½, the life expectancy factor for age 70 will be used for those born between January 1 and June 30th, while age 71 will be used for those born between July 1 and December 31.
Key components of these revised regulations were the introduction of a new life expectancy table to be used by most IRA owners and plan participants and increases in life expectancy factors for the two existing tables, reflecting the longer lives lived by modern-day individuals. Introduction of the new life expectancy table was also an attempt by the IRS to answer pleas made by consumers and practitioners for simplification of the RMD rules, which were considered extremely onerous to satisfy and often resulted in financially severe consequences to those unable to master their complexities.
These life expectancy tables are identified and described below, and are also available at our website (www.irahelp.com) under the “IRA Resources” tab, as well as in Appendix C of IRS Publication 590 (www.irs.gov under “Forms and Publications”). It is critically important that RMDs be calculated using the appropriate life expectancy table. Any shortfall in the timely payment of an RMD may result in the assessment of an IRS excise tax penalty equal to 50% of the amount not withdrawn. As you can see, our government is deadly serious about the accurate and timely payment of RMDs from IRAs and other retirement plans.
Uniform Lifetime Table
The Uniform Lifetime Table, introduced via the revised proposed regulations of 2001 and incorporated into the final regulations of 2002, is used only by IRA owners and plan participants for calculating lifetime-required distributions. Under this table, the beneficiary is considered to be exactly 10 years younger than the owner or participant, regardless of the beneficiary’s actual age or even if no beneficiary has been designated.
Users of this table reference it annually to obtain the new life expectancy factor for the year. An individual can’t outlive it as it never reaches zero. Beneficiaries never use this table.
Joint Life Expectancy Table
The Joint Life Expectancy Table is used only by IRA owners and plan participants whose sole beneficiary for the entire year is their spouse who is more than 10 years younger. Use of this table provides for a longer life expectancy factor than that yielded by the Uniform Table, resulting in a smaller RMD.
The “sole beneficiary for the entire year” rule is determined using the IRA owner’s or plan participant’s marital status as of January 1 of each year. It is satisfied even if the spouse beneficiary dies during the year, regardless of whether a new beneficiary is named. It also applies in the case of divorce, provided a new beneficiary is not named in the same year.
As is the case with the Uniform Lifetime Table, owners reference this table each year to obtain their new life expectancy factor for RMD purposes, they can’t outlive the table, and beneficiaries are never allowed to use it.
It should also be noted that IRA owners and plan participants are allowed to switch between the Uniform Lifetime Table and the Joint Life Expectancy Table if any beneficiary changes they make from one year to the next qualifies them to do so.
Single Life Expectancy Table
The Single Life Expectancy Table is used only by beneficiaries to compute RMDs on inherited retirement accounts. It can never be used by IRA owners or plan participants to compute their lifetime-required distributions.
This table is accessed only once, in the year following the year of the IRA owner or plan participant’s death, to determine the beneficiary’s life expectancy factor. This life factor is then reduced by one in each passing year until it is fully exhausted.
There is an exception for spouses who are the decedent’s sole beneficiary and don’t take over the account as their own (or rollover the assets into a retirement account in their own name). They use the table annually to recalculate their life expectancy factor for the new year. These spouses can never outlive the table.
Each table yields a specific life expectancy factor for a given distribution year. The market value of the IRA or retirement plan in question as of the previous December 31 is divided by the applicable life expectancy factor, resulting in the correct RMD amount to be paid for the year. Once this minimum is satisfied, account owners and beneficiaries can always take more than the minimum amount. So, even with simplification, the RMD rules remain complicated. The assistance of a financial advisor who is trained in the nuances of this topic will be very valuable when it comes time for you to begin taking RMDs.
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