BASIC RULES OF REQUIRED DISTRIBUTIONS
Generally, if you own a retirement plan, you can take money out any
time you like. You may have to pay a penalty if you take money out
too soon, but the money is there for you.
The rules I discuss here are concerned mostly with when the law requires
you to take the money out. Most of the time, you have to pay income
tax on all the money you take out.
Disclaimer: to make these basic rules intelligible, I fudged a few
places and broke off some square corners. Please don't make any decisions
based on these rules alone--they are designed just to get you started
in the right direction. If you find yourself dealing with any of this,
seek expert help. These rules are unisex--a widower is treated the
same as a widow:
- Participant. A ``participant'' is the person who earned
the retirement account. (If a spouse inherits a retirement account
and ``rolls over'' the account, she is then treated as if she
earned the account.)
- Designated beneficiary. When a participant dies, the retirement
account goes to some beneficiary. A ``designated beneficiary''
is a human being (with a life expectancy you can establish). You can
have several designated beneficiaries (like ``my children'').
An estate of a dead person is not a designated beneficiary. Trusts
generally fail to qualify as a designated beneficiary. Is some situations,
maybe a real simple trust for one human being (a so-called ``see-through
trust'') can be a designated beneficiary.
The advantage to being a designated beneficiary is that you may be
able to get a ``stretch-out.'' Then you may be able to keep the
tax shelter of the retirement plan going for your benefit for a long
time. A beneficiary not qualified as ``designated'' will not get
a stretch-out and will often have to accept all the retirement account
in one payment. This could cause a big ``spike'' in income tax
for the year the inheritance comes in, and there will be no more tax
shelter.
- Modes of distribution. A retirement plan is distributed to
the participant in one of the following ways:
- In a lump sum
- In an annuity over his life (like $2,000 a month until he dies, which
leaves no inheritance for children or others)
- In a joint annuity over his life and that of a designated beneficiary
(like $1,500 a month until both he and his wife have died, which
leaves no inheritance for children)
- In payments over his life expectancy (now there can be money left
over to be inherited by children)
- In payments over the joint life expectancy of the participant and
a designated beneficiary (here too there can be money left over to
be inherited by children)
- Required beginning date. The participant must take the lump
sum payment or start a pay-out by the ``required beginning date.''
This is April 1 (not April 15) following the year in which the participant
is age 70 12.
- However, an employee of a company (that the employee does not control)
can delay the required beginning date for retirement plans (other
than IRAs) until the time he retires. Participants in government and
church plans get a similar break.
- If you hit age 70 and you still have money in retirement plans, you
need to be sure you know how all this works. If you fail to take out
your required minimum distributions on time, there can be serious
penalties (50% of the amount you failed to distribute).
- Life expectancy mode. Most affluent participants will elect
to take the required distributions over a life expectancy so as to
enhance the prospects of inheritance by children.
- There is a Uniform Lifetime Table (``ULT'') that most people,
single or married, will use for figuring out their required minimum
distributions. This table is surprisingly liberal in favor of participants.
The ULT allows participants who can afford it to leave money in the
retirement plan longer so as to keep earning money free of income
tax. (Most participants, however, have to take fund out faster than
the ULT requires because they need the money for living expenses.)
- If you are married and your spouse is more than 10 years younger than
you, there is a special table for you to use that is even more liberal
than the ULT.
- Death before RBD. If the participant dies before the required
beginning date (i.e., a younger participant):
- If the designated beneficiary is a widow, see the special rules below.
- If there is a designated beneficiary who is not a widow, the law allows
payments to that designated beneficiary over his single life expectancy.
This can allow the beneficiary to keep the tax shelter of the retirement
plan working for him for a long time. Some retirement plans (especially
IRAs) have this flexibility built in to help relatives (children,
grandchildren, etc.) as well as significant others.
- Alas, many retirement plans (especially 401(k)s) don't allow payments
over long periods of time to non-spouse beneficiaries (even though
the law permits it). But beginning in 2008, these retirement plans
must give non-spouse designated beneficiaries the option of transferring
their accounts to a special inherited IRA. Then the beneficiary can
stretch out the distributions over his life expectancy.
- If there is no designated beneficiary, payments can be made over five
years to whomever gets the money (often the estate of the participant)
if the plan allows that. Otherwise, the beneficiary may be stuck with
taking a lump sum.
- Generally, the beneficiary gets sufficient time to deal with the details
of his inherited retirement. But don't run the risk of missing a deadline.
Get started on this as soon as possible.
- Death after RBD. If the participant dies after the required
beginning date (i.e., an older participant) then payments out of the
plan to the participant are already underway:
- If the designated beneficiary is a widow, see the special rules below.
- If there is a designated beneficiary who is not a widow, the law allows
payments over the longer of the single life expectancy of the beneficiary
or the single life expectancy of the participant. This can allow the
beneficiary to keep the tax shelter of the retirement plan working
for him for a long time. Some retirement plans (especially IRAs) have
this flexibility built in to help relatives (children, grandchildren,
etc.) as well as significant others.
- Alas, many retirement plans (especially 401(k)s) don't allow payments
over long periods of time to non-spouse beneficiaries (even though
the law permits it). But beginning in 2008, these retirement plans
must give non-spouse designated beneficiaries the option of transferring
their accounts to a special inherited IRA. Then the beneficiary can
stretch out the distributions over the longer of the single life expectancy
of the beneficiary or the single life expectancy of the participant.
- If there is no designated beneficiary, whoever gets the money can
stretch out receipt of the funds over the single life expectancy of
the participant (if the plan permits this).
- Because the participant is already taking distributions in this situation,
the beneficiary should undertake to deal with this immediately. There
must be a distribution for the year of death and each year thereafter
(there is no hiatus as in the situation when the participant dies
before the RBD).
- Widow remains beneficiary. If the designated beneficiary
is the participant's spouse, she can continue to treat herself as
the beneficiary of the participant's IRA and doesn't have to take
anything until the participant would have been 70 12.
- This is not a rollover. This is probably a better choice than a rollover
for younger widows of moderate means who will need to spend money
from the participant's plan for living expenses. Under this approach,
she will not be burdened with a 10% tax on any distributions prior
to the time she is 59 12.
- The widow doesn't have to do anything to get this treatment. Remaining
a beneficiary is the default.
- Widow rolls over. The widow also has the right to rollover
the account to her own IRA. Once rolled over, the account is treated
as if the widow were the participant who earned the funds. If she
needs money from the IRA before age 59 12, this can expose her to a
10% tax which probably could have been avoided. Most older widows
will want to rollover. This ``fresh start'' has 3 big advantages:
- It can delay in many cases the required beginning date for the widow
to start taking distributions.
- Once the required beginning date arrives, the widow will have use
of the liberal ULT.
- The designated beneficiaries of the widow can, when they inherit from
her, withdraw funds over their life expectancies.
- Roth IRA. Generally, retirement plans were designed to provide
retirement security and not to be vehicles for inheritance by others.
Roth IRAs provide both retirement security and an excellent way to
leave an inheritance. Distributions (after an initial holding period)
are always free of income tax to the participant. The participant
never has to take money out. When the participant dies, the beneficiary
can take all the money out immediately with no income tax.
Can the beneficiary also leave money in the plan for a stretch-out
of the tax shelter? Yes. But the beneficiary is limited to the same
minimum distribution rules that apply to a traditional IRA when the
participant dies before his RBD--the life expectancy of the beneficiary
(if he happens to fit the definition of a designated beneficiary)
or the five-year rule.