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Kyle is an eligible designated beneficiary of his father's traditional IRA (he is also the only beneficiary). Kyle's father, Albert, retired at the age of

Kyle is an eligible designated beneficiary of his father's traditional IRA (he is also the only beneficiary). Kyle's father, Albert, retired at the age of 62 and he passed away at the age of 68 on April 5, 2025. Albert's birthday would have been November 6th during the year. Kyle turns age 48 on June 2, 2025. The value of the account is $5,500,000 as of December 31, 2024. The value of the account is $5,300,000 as of December 31, 2025. The value of the account is $4,700,000 as of December 31, 2026.

1. According to Treas. Reg.1.401(a)(9)-2 and IRC401(a)(9)(C), did required minimum distributions begin for Albert before Albert's death?

2. How rapidly should Albert's IRA funds be distributed to Kyle according to IRC 401(a)(9)(B)(ii) and Treas. Reg.1.401(a)(9)-3? [Compare to IRC 401(a)(9)(H)]

  • What distribution method is available to Kyle according to IRC 401(a)(9)(B)(ii)?
  • What longer distribution method is available to Kyle under IRC 401(a)(9)(H)(i)?
  • What additional method of distribution is available to Kyle under IRC 401(a)(9)(B)(iii)? [Compare to (B)(ii) and (H)(i)].

3. What is Kyle's due date for removing all funds from the account if he is trying to satisfy the 10-year rule according to Treas. Reg.1.401(a)(9)-3?

  • Do the regulations explain Kyle's due date for removing all funds from the account if he is trying to satisfy the 10-year rule? If not, take your best guess as to what this due date would be?

4. Suppose that Kyle would like to use the life-expectancy distribution method as an eligible designated beneficiary.

  • What actuary table should Kyle use to calculate his distribution period for his first beneficiary RMD according to Treas. Reg.1.401(a)(9)-5?
  • How should Kyle determine the distribution period for his second beneficiary RMD? Will he be allowed return to the actuary table?
  • What is the due date of Kyles first beneficiary RMD?
  • What is the dollar amount of Kyles first beneficiary RMD?
  • What is the due date of Kyles second beneficiary RMD?
  • What is the dollar amount of Kyles second beneficiary RMD?

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