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RMD Tables To Be Updated

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Required Minimum Distributions: RMD’s

Section 401(a)(9) requires most retirement plans and individual retirement accounts to make required minimum distributions (“RMDs”) over the lifetime of the individual (or the lifetime of the individual and certain designated beneficiaries) beginning no later than such individual’s required beginning date (generally, April 1 in the year following attainment of age 72). This minimum amount is determined by dividing the individual’s account balance by the applicable distribution period found in one of the life expectancy and distribution tables (the “Tables”).

On November 12, 2020 the Department of Treasury is scheduled to publish final regulations updating the Tables, which is in response to an Executive Order issued in August of 2018 directing the Secretary of the Treasury to review the Tables to determine if they should be updated to reflect current mortality data.

RMD’s Tables are being updated

Longer Life Expectancies Reflected

The updated Tables will generally reflect longer life expectancies than presently reflected in the current Tables last published based on 2003 mortality rates. For example, the current Tables use a life expectancy of 25.6 years for a 72-year-old for purposes of calculating the RMD while the updated Tables will use a life expectancy of 27.4 years. This will result in reduced RMDs, enabling individuals to retain larger balances in retirement accounts to account for the possibility of living longer.

The updated Tables will be effective for distributions beginning on or after January 1, 2022 and will include a transition to ‘re-set’ the life expectancy for certain individuals already receiving RMDs based on the prior Tables. For example, an individual who attains age 72 in 2021 will be required to take an RMD no later than April 1, 2022. The updated Tables will not apply to calculate the individual’s 2021 RMD (paid on or before April 1, 2022), but the updated Tables will apply to the 2022 RMD (paid on or before December 31, 2022). The regulations do not include periodic automatic updates to the Tables. Instead, the Treasury and IRS will review the Tables at the earlier of 10 years or whenever a new study of mortality experience is published. The final regulation and new Tables can be found here.

Impact on Medicaid and Estate Planning

RMD’s are a factor that every estate planner must consider into calculations of income and assets for Medicaid eligibility. Understanding the new tables and income that will be forced out to a individual or spouse is important to know as there are minimum and maximum income limits. A personal consult with an estate planning attorney can best illustrate the impact this will have on your plan.

Should I Convert To A ROTH IRA?

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What is the difference between a Roth IRA and a Traditional IRA?

Roth IRA is an individual retirement account that offers tax-free growth and tax-free withdrawals in retirement. Roth IRA rules dictate that as long as you’ve owned your account for 5 years and you’re age 59½ or older, you can withdraw your money when you want to and you won’t owe any federal taxes.

A Traditional IRA is a type of individual retirement account that lets your earnings grow tax-deferred. You pay taxes on your investment gains only when you make withdrawals in retirement.

In addition, when planning for an considering long term care planning and possibly needing to qualify for Medicaid, most states do not deem Qualified Accounts such as 401(K)’s and IRA’s and Roth IRA’s as countable resources.

Therefore, the decision to make is: Do I take the income tax hit now and convert to a Roth IRA, or do I wait take it later when I start drawing down on the traditional IRA or 401(K)?

Should I Convert to a Roth IRA?

Roth IRA conversions have been available for many years. Two recent developments suggest that you reconsider Roth IRA conversions for yourself in 2020:

  • The government’s response to COVID-19 significantly raises the Federal deficit, making it more likely that tax rates will be going up in the future.
  • You may be in a lower tax bracket in 2020, which would reduce the tax cost of the conversion.

Both of these factors make Roth IRA conversions more attractive than they were in 2019. The decision as to whether these factors tip the scale in favor of a Roth IRA conversion will require careful consideration. You will need to consider your overall financial plan and make certain assumptions.

Who should do a Roth IRA conversion?

The ideal candidate for a Roth IRA conversion would check off most or all of these boxes:

  • You can pay the tax on the conversion out of a taxable investment portfolio.
  • You expect that you will be in the highest income tax bracket in the future when IRA distributions would be required.
  • You expect that you will not need to withdraw funds from the Roth IRA during your lifetime.
  • You expect that your estate will be subject to estate tax at your death and your spouse.

Who should not do a Roth IRA Conversion?

Some people who should not do a Roth IRA conversion currently are as follows:

  • People who expect to be in a lower tax bracket at retirement.
  • People who can use IRA distributions to take advantage of the lower brackets.
  • People who want to preserve the option of using income from their IRA to offset future medical costs for long-term care or other significant medical expenses, bearing in mind the the principal balances are protected and currently not deemed a countable resource in many states.
  • People who plan to use their IRA for charitable contributions.

Want to discuss how conversion will impact you? Contact us for a no obligation consultation.

SOURCE: LISI Employee Benefits & Retirement Planning Newsletter #737 (June 9, 2020)