One of our IRA customers died last year. The customer had reached the age for required minimum distributions (RMDs), but he did not take his distribution for 2015 before dying. The IRA had two beneficiaries, a son and daughter. The son opened an inherited IRA, and the daughter took her portion as a lump sum distribution. Should we have taken out the RMD before distributing the IRA to the son and daughter?

No, your institution generally is not responsible for taking out the RMD (unless you have agreed to do so in your account agreement). When an IRA owner dies after reaching the age of 70 ½, the IRA’s beneficiaries are responsible for distributing the owner’s RMD for the year of death — it is not your responsibility to distribute the RMD. In addition, your institution’s responsibility to annually report the RMD to the IRA owner does not apply in the year of the owner’s death.

However, because the son is now the beneficiary of an inherited IRA, your institution should annually report the RMDs for his portion of the IRA going forward (assuming the son established his IRA with your institution), based on the RMD rules for inherited IRAs. Because the daughter already has withdrawn her entire portion of the IRA and paid taxes on it, she is not required to take any further distributions.

For resources related to our guidance, please see:

  • IRS Publication 590b, IRA Distributions in the year of the owner’s death (“If the owner died on or after the required beginning date, the IRA beneficiaries are responsible for figuring and distributing the owner’s required minimum distribution in the year of death. . . .”)
  • IRS Publication 590b, Statement of required minimum distribution (“If an RMD is required from your IRA, the trustee, custodian, or issuer that held the IRA at the end of the preceding year must either report the amount of the RMD to you, or offer to calculate it for you. . . . No report is required . . . for IRAs of owners who have died.”)
  • IRS Publication 590b, Separate Accounts  (“Separate accounts. A single IRA can be split into separate accounts or shares for each beneficiary. . . .  these separate accounts or shares will not be combined for required minimum distribution purposes after the death of the IRA owner if the separate accounts or shares are established by the end of the year following the year of the IRA owner’s death.”)