I believe I'm also seeing the following "nuance" in the timing of these issues -
Can anyone confirm if this is accurate?
Sec 327 of the Secure act already "allows" the surviving spouse to be treated as employee/(owner if IRA) for sake of RMD's, with the provision of using the Uniform Table (at least if deceased spouse hadn't reached their RMD). This went into effect 1-1-2024, and I believe the presumption is, it has/had to be elected. Then the finalized regs said the election is automatic - but the final regs don't go into effect until 01-01-2025.
SO, for Calendar year 2014, the election would have to be in place for it to apply- and it can only apply when the FIRST RMD is due in 2014 (or later year, if we were discussing 2015 onwards, but-)- (my understanding is that the new provision doesn't apply to any RMD's that Started before 2014).
For a employee/owner who died on or AFTER their RBD however, while Sec 327 also I believe makes provision for the same RMD treatment(?) (uniform table), it MUST be elected -even in the final regs. However the new 2024 Proposed regs would allow a Plan to make it the default election.
Can anyone confirm if this is accurate?
Sec 327 of the Secure act already "allows" the surviving spouse to be treated as employee/(owner if IRA) for sake of RMD's, with the provision of using the Uniform Table (at least if deceased spouse hadn't reached their RMD). This went into effect 1-1-2024, and I believe the presumption is, it has/had to be elected. Then the finalized regs said the election is automatic - but the final regs don't go into effect until 01-01-2025.
SO, for Calendar year 2014, the election would have to be in place for it to apply- and it can only apply when the FIRST RMD is due in 2014 (or later year, if we were discussing 2015 onwards, but-)- (my understanding is that the new provision doesn't apply to any RMD's that Started before 2014).
For a employee/owner who died on or AFTER their RBD however, while Sec 327 also I believe makes provision for the same RMD treatment(?) (uniform table), it MUST be elected -even in the final regs. However the new 2024 Proposed regs would allow a Plan to make it the default election.
Statistics: Posted by ValHadl — Mon Oct 21, 2024 12:04 am — Replies 10 — Views 2142