Spousal beneficiary options just got (a bit) more complicated under proposed RMD regulations

The IRS has always treated IRA (and qualified plan) spouse beneficiaries quite generously. But the new RMD rules may make executing certain options more complicated. These two spouse beneficiary changes have drawn the most attention: a new deadline for spouse beneficiaries to treat inherited IRA assets as their own, and a new “hypothetical RMD” that may apply to certain spouse beneficiaries.

Deadline for Spouse Beneficiaries Treating the IRA as Their Own

Existing Regulations – Under the current rules, the surviving spouse of an IRA owner has the option to “treat as own” at any time and at any age, as long as the surviving spouse is the sole beneficiary or, if there are multiple beneficiaries, separate accounting has been applied timely. The existing regulations also define “treat as own” narrowly. Spouse beneficiaries are deemed to treat an IRA as their own if they:

  • transfer the IRA assets to their own IRA,
  • make a contribution to the inherited IRA, or


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