RMDs: New Rules and “Bigger” Problems

One often-overlooked component in retirement planning is the impact of required minimum distributions (RMDs). In this post, we explore what RMDs are, the recent changes, and the potential impact of these changes on you and your heirs.

Congress enacted Internal Revenue Code Section 401(k) in 1978. We are just starting to see the first generation of workers retiring who were offered employer-sponsored retirement plans for their entire working careers. This is leading to a good problem—very large account balances.

But many of these workers will have high taxable income at their required beginning date. This generation of retirees is often surprised by just how much tax they will pay from their retirement accounts.

Many will face substantial RMDs, given how much they saved over the past several decades. While saving is always a good thing, the tax ramifications need to be addressed.

What Are RMDs?

RMDs are mandatory withdrawals from certain qualified retirement accounts (i.e., traditional IRAs or employer-sponsored plans) at a specified age.

The purpose is to help spread out the distribution of your retirement accounts over your lifetime. RMDs ensure that you can’t defer taxation until the money is inherited by another. They help generate hundreds of millions in annual tax revenue.

Generally speaking, you calculate RMDs by dividing the prior year-end balance by your IRS life expectancy factor. Various calculators can assist in calculating your annual requirements.

Recent Changes to RMD Rules

Several recent changes to the RMD rules may affect your retirement planning. The first was in 2019 with the Setting Every Community Up for Retirement Enhancement (SECURE) Act, which raised the age for starting RMDs from 70 ½ to 72. 

In December 2022, Congress passed SECURE Act 2.0, which among other things, changed the RMDs for many Americans. If you turn age 72 after the 2022 calendar year, your RMD start date is based on the guideline below: 

  • Birth year: 1951-1959 = Age 73

  • Birth year: 1960 or later = Age 75

The “still working” exception allows you to delay RMDs in active employer-sponsored plans [i.e., 401(k), 403(b), Thrift Savings Plan]. This exception does not apply to IRAs.

  • Joe, age 77, has all his retirement savings in his IBM 401(k). Joe is not required to take RMDs as long as he continues to work for IBM. If Joe were to retire in 2024, he would be subjected to annual RMDs.

How the New RMD Rules May Affect Retirement Planning and Tax Planning Strategies

These changes allow many to delay their mandatory withdrawals, which can offer greater flexibility in retirement and can open several tax planning strategies. Deferring withdrawals allows your investments to compound for a longer period. In addition, delaying them can reduce your tax burden in those respective years.

An effective strategy could be to look at delaying withdrawals until later in retirement. This allows you to maximize investment growth and boost your retirement income. Another approach is to consider Roth IRA conversions, which can provide tax-free retirement assets and reduce future RMD amounts. 

Let’s look at an example:

  • Mary, born in 1951 (age 72), has a $2 million IRA. Thanks to the recent changes, her RMDs won’t start until 2024 (age 73). This allows Mary’s investments to grow uninterrupted for an additional year and save a considerable amount in taxes. 

If not for the change, Mary’s RMD in 2023 would have been ~$80,000, which is ~$24,000 in taxes (assuming a 30% tax bracket). This additional income could have also pushed Mary into a higher tax bracket! In addition, her RMDs could subject her to Medicare surcharges, better known as IRMAA (income-related monthly adjustment amount). 

Given Mary’s lower taxable income in 2023, it could make sense to withdraw a smaller amount from her IRA and pay the tax while in a lower bracket. If Mary does not need these funds for an extended period, she could explore Roth conversions, which may provide sizable tax benefits to both her and her heirs.

Now, if Mary needs $80,000 from her IRA to meet her financial obligations, the potential tax benefits above are eliminated. With proper planning, Mary should have money in various tax buckets, providing the necessary flexibility to take advantage.

Overall, you need to consider how the new RMD rules may impact your retirement planning and tax strategies. Talking to a fiduciary fee-only financial advisor can help you develop a comprehensive retirement plan that considers your unique financial situation, goals, and needs. This can help provide you and your family peace of mind and financial security throughout your retirement.

Impact of RMDs on Estate Planning

RMDs can have significant implications for estate planning, particularly if you plan on leaving a large amount of retirement savings to your heirs.

Spouses can inherit each other’s retirement accounts and transfer them into their own without tax consequences. The problem arises when the inheritor is a non-spouse. The passage of the SECURE Act eliminated the stretch IRA. It required non-spouse beneficiaries to liquidate their entire account balance within 10 years of the original IRA owner’s death, with few exceptions.

These withdrawals are taxed as ordinary income in addition to other income earned in those respective years. Failing to take RMDs can result in significant penalties, so beneficiaries need to understand the rules governing inherited retirement accounts. 

Additionally, RMDs may increase the size of an individual’s estate, which can have implications for estate taxes. Therefore, it is important to incorporate RMDs into a comprehensive estate plan. Other strategies—such as making qualified charitable distributions (QCDs) or funding a charitable remainder unitrust (CRUT) or a charitable remainder annuity trust (CRAT)—can be useful but should be explored on a case-by-case basis.

With proper planning, taking advantage of the delayed RMD requirements can save you and your heirs a significant amount in taxes. 

Conclusion

Required minimum distributions are an important part of retirement planning, and the recent changes will have significant implications for countless retirees and families. This isn’t the first time the rules have changed with respect to retirement accounts and surely won’t be the last.

Educating yourself on your options is of the utmost importance and will help you feel more comfortable that you have explored all the possible avenues for you and your heirs.

Discuss your situation with a fee-only financial advisor.

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