November 2021

2022 Requirement to Reset the Divisor for a Beneficiary Using the Life Distribution Rule

The IRS finalized a number of revisions to its RMD regulation on November 12, 2020. The IRS issued new life expectancy tables to be used for 2022 RMD calculations and the IRS issued three transition rules.

Transition Rule #1. A beneficiary using the standard life distribution rule was required to determine their distribution period or divisor. This distribution period commenced for calendar years following the year the IRA accountholder died. The distribution period depended on the age of the beneficiary in that first year and using the Single Life Table. The divisor for subsequent years is determined by subtracting 1.0 for each subsequent year. Under the transition rule, the initial divisor (i.e. the initial life expectancy) is reset by using the divisor from the new Single Life Table for the initial year. Then, that reset divisor is determined by subtracting 1.0 for each subsequent year. This reset procedure applies to RMD calculations for 2022 and subsequent years.

Example: Jane Doe an IRA owner, died in 2012 at age 77. Her beneficiary was her son, Mark, whose date of birth is 2/17/70. He was age 43 in 2013. The divisor which applies for 2022 will be 33.9. The initial divisor of 40.7 for 2013 is replaced by 42.9 and the revised schedule applies to 2022 and subsequent years.