The IRS has announced an important delay in implementing certain required minimum distribution (RMD) regulations tied to the SECURE 2.0 Act of 2022. Originally set to take effect in 2025, these new rules will now be postponed until 2026, giving retirement account holders and financial professionals additional time to adjust to the changes.
This delay follows concerns raised by financial professionals and taxpayers during a public hearing in September 2024, as well as through written feedback to the IRS. Until the final regulations take effect, the IRS advises taxpayers to make a good faith effort in complying with the provisions.
Key Changes and Clarifications in the Proposed RMD Rules
While the delay provides more time to prepare, the proposed regulations introduce several critical clarifications regarding RMDs, Roth accounts, and spousal elections. Here’s what you need to know:
1. Clarification on RMD Age for Those Born in 1959
One of the most notable issues in the SECURE 2.0 Act was an inconsistency in the wording that suggested individuals born in 1959 might have to start taking RMDs at either age 73 or 75. The proposed regulations clarify that the correct RMD starting age for this group is 73.
2. Roth Accounts and RMDs
A significant change introduced in SECURE 2.0 was the exemption of Roth accounts in employer-sponsored plans (such as 401(k)s and 403(b)s) from RMD requirements, aligning them with Roth IRAs. The new proposed regulations go a step further, specifying that distributions from Roth accounts will not count toward fulfilling a participant’s RMD for the year.
This clarification is crucial for individuals who hold both pre-tax and Roth retirement assets, as it affects withdrawal strategies and tax planning.
3. Spousal Election to Be Treated as the Employee
SECURE 2.0 introduced a provision allowing a surviving spouse to elect to be treated as the deceased employee for RMD purposes, potentially delaying distributions. The IRS’s proposed regulations clarify several points regarding this rule:
- The spousal election is available only if the deceased employee was required to begin RMDs in 2024 or later.
- If the employee passes away before reaching their required beginning date, the surviving spouse automatically assumes the employee’s status.
- If the employee dies after their RMDs have begun, the surviving spouse does not automatically receive this treatment unless the terms of the retirement plan specifically allow for it.
- If the surviving spouse later passes away after their own RMDs have started, their beneficiaries will be classified as non-eligible designated beneficiaries, meaning they must deplete the account within 10 years.
What This Means for Your Retirement Planning
With these delays, there is additional time to reassess your retirement strategy. Key considerations include:
- Adjusting withdrawal plans if you were affected by the 1959 RMD age confusion.
- Reviewing Roth conversion strategies since distributions from Roth accounts do not satisfy RMDs.
- Understanding the spousal election rule, especially for couples managing retirement distributions together.
Take Control of Your Retirement Plan
At Samalin Wealth, we’re here to help navigate these evolving regulations and ensure your retirement strategy aligns with the latest rules. If you have questions about how these changes impact you, schedule a meeting with our team today.
