How this calculator is verified

The inherited IRA calculator

An inherited IRA is not one rule but a grid of them, and which one governs turns on when the owner died, whether they had reached their required beginning date, and who inherited. The grid below is exhaustive: every combination of those facts resolves to exactly one rule or to one case we decline, and there is no path that produces a blank.

That is the claim this section is here to let you check. The rules come first, then every case the engine is run against on each build, then the cases we will not compute at all and what to ask a custodian for instead.

The rules it computes

• The owner died before 2020, and the surviving spouse has already treated the IRA as their own.

  What that means for the money: Hands to Door 1's owner math, and says so plainly.

  • Treas. Reg. 1.408-8(c)(1) (verified 2026-08-26)

• The owner died before 2020 and before their required beginning date, and the surviving spouse remains a beneficiary rather than the owner.

  What that means for the money: Commencement deferred to the year the owner would have attained the applicable age, then recalculated annually.

  • Treas. Reg. 1.401(a)(9)-3(d) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-2(b)(2)(ii) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-5(d)(3)(iv) (verified 2026-08-26)
  • Treas. Reg. 1.408A-6, A-14(b) (verified 2026-08-26)

• The owner died before 2020 and on or after their required beginning date, and the surviving spouse remains a beneficiary rather than the owner.

  What that means for the money: Greater-of denominator.

  • Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) (verified 2026-08-26)

• The owner died before 2020 and before their required beginning date, and the beneficiary is an individual who is not the spouse.

  What that means for the money: Fixed term reduced by one, anchored at the year after death, with the 2022 reset.

  • Treas. Reg. 1.401(a)(9)-5(d)(3)(iii) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-9(f)(2)(ii)(A) (verified 2026-08-26)

• The owner died before 2020 and on or after their required beginning date, and the beneficiary is an individual who is not the spouse.

  What that means for the money: Greater-of denominator, with the 2022 reset applied to the beneficiary's term.

  • Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-9(f)(2)(ii)(A) (verified 2026-08-26)

• The owner died in 2020 or later, and the surviving spouse has already treated the IRA as their own.

  What that means for the money: Hands to Door 1's owner math, and says so plainly.

  • Treas. Reg. 1.408-8(c)(1) (verified 2026-08-26)

• The owner died in 2020 or later and before their required beginning date, and the surviving spouse remains a beneficiary rather than the owner.

  What that means for the money: Deferred to the year the owner would have reached applicable age, then recalculated annually.

  • Treas. Reg. 1.401(a)(9)-3(d) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-2(b)(2)(ii) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-5(d)(3)(iv) (verified 2026-08-26)
  • Treas. Reg. 1.408A-6, A-14(b) (verified 2026-08-26)

• The owner died in 2020 or later and on or after their required beginning date, and the surviving spouse remains a beneficiary rather than the owner.

  What that means for the money: Greater-of denominator.

  • Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) (verified 2026-08-26)

• The owner died in 2020 or later and before their required beginning date, and the beneficiary is a designated beneficiary who is not an eligible designated beneficiary.

  What that means for the money: No annual minimum; account empty by 31 December of year 10.

  • Treas. Reg. 1.401(a)(9)-3(c)(3) (verified 2026-08-26)

• The owner died in 2020 or later and on or after their required beginning date, and the beneficiary is a designated beneficiary who is not an eligible designated beneficiary.

  What that means for the money: Annual minimum on the greater-of denominator and empty by year 10.

  • Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-5(d)(1)(i) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-5(e)(2) (verified 2026-08-26)

• The owner died in 2020 or later and before their required beginning date, and the beneficiary is an eligible designated beneficiary who is disabled, chronically ill, or not more than ten years younger than the owner.

  What that means for the money: Lifetime, reduced by one.

  • Treas. Reg. 1.401(a)(9)-5(d)(3)(iii) (verified 2026-08-26)

• The owner died in 2020 or later and on or after their required beginning date, and the beneficiary is an eligible designated beneficiary who is disabled, chronically ill, or not more than ten years younger than the owner.

  What that means for the money: Lifetime, on the greater-of denominator.

  • Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) (verified 2026-08-26)

• The owner died in 2020 or later and before their required beginning date, and the beneficiary is a minor child of the owner.

  What that means for the money: Reduced by one until 21, then annual distributions continue alongside the terminal deadline measured from reaching 21.

  • Treas. Reg. 1.401(a)(9)-4(e)(9) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-4(e) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-4(e)(3) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-5(d)(3)(iii) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-3(c)(4) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-5(e)(4) (verified 2026-08-26)

• The owner died in 2020 or later and on or after their required beginning date, and the beneficiary is a minor child of the owner.

  What that means for the money: Greater-of until 21, then annual distributions continue alongside the terminal deadline measured from 21.

  • Treas. Reg. 1.401(a)(9)-4(e)(9) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-4(e) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-4(e)(3) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-5(d)(1)(i) (verified 2026-08-26)
  • Treas. Reg. 1.401(a)(9)-5(e)(4) (verified 2026-08-26)

The cases it is checked against, on every build

Each expected answer below was worked out from the regulation by hand before the code that computes it existed, so these cases can show the software is right rather than only that it agrees with itself.

• A beneficiary aged 76 in the year after an owner who died in 2019

  Expected value derived from the authority

  The regulation's own worked example of the 2022 table reset, extended to the current year.

  Divisor for 2026

  8.1

  How this was worked out: Treas. Reg. 1.401(a)(9)-9(f)(2)(ii)(B): an employee dies at 80 in 2019 and the non-spouse designated beneficiary is 75 in the year of death. The relevant calendar year is 2020, the year after death, because Treas. Reg. 1.401(a)(9)-5(d)(3)(iii) anchors a non-spouse beneficiary's remaining life expectancy at the beneficiary's age in the calendar year FOLLOWING the year of death, not at the age in the year of death. The beneficiary is 76 in 2020, so age 76 is the lookup and age 75 is not. Under the current Single Life Table age 76 is 14.1. The regulation states the 2022 denominator is 12.1, being 14.1 reduced by 2. Extending the same reduction, 2026 is 2026 minus 2020 equals 6 years elapsed after the anchor year, so 14.1 minus 6, which is 8.1. Note the 2020 CARES waiver did not stop the minus-one clock: the regulation's own figures advance through 2020. Greater-of does not displace this: the owner's own remaining life expectancy is age 80 in 2019, which is 11.2, reduced by 7 for 2026, which is 4.2, and 8.1 is greater.

  Technical details

  Case

  reset-2022-regulation-example

  Inputs

  {"kind":"divisor","ownerDeathYear":2019,"beneficiaryAgeInYearAfterDeath":76,"method":"fixedTermMinusOne"}

  Expected

  {"kind":"divisor","year":2026,"divisor":8.1}

• A beneficiary aged 76 in the year after an owner who died in 2019

  Expected value derived from the authority

  The same example at the exact year the regulation states, so the method is pinned to a printed answer and not only to our extension of it.

  Divisor for 2022

  12.1

  How this was worked out: Treas. Reg. 1.401(a)(9)-9(f)(2)(ii)(B) states in terms that the 2022 applicable denominator is 12.1 years, being the 14.1-year life expectancy for a 76-year-old under the current Single Life Table reduced by 2 years. Read from the eCFR versioner API, title 26, issue date 2026-08-24. No arithmetic of ours stands between the regulation and this number.

  Technical details

  Case

  reset-2022-regulation-example-stated-year

  Inputs

  {"kind":"divisor","ownerDeathYear":2019,"beneficiaryAgeInYearAfterDeath":76,"method":"fixedTermMinusOne"}

  Expected

  {"kind":"divisor","year":2022,"divisor":12.1}

• A beneficiary aged 119

  Expected value derived from the authority

  Age 119 is a real table row, not part of the terminal clamp. Its neighbour proves the clamp is a clamp.

  Divisor for 2026

  1.1

  How this was worked out: Treas. Reg. 1.401(a)(9)-9(b), Table 1, publishes ages 0 through 119 plus a terminal row of '120 and over'. Age 119 is 1.1, distinct from the terminal 1.0. This case exists so that age-120-floor cannot pass by a function that returns 1.0 for everything at the top of the table, which is exactly how an abridged transcription would look.

  Technical details

  Case

  age-119-not-clamped

  Inputs

  {"kind":"divisor","attainedAge":119,"method":"tableLookup"}

  Expected

  {"kind":"divisor","year":2026,"divisor":1.1}

• A beneficiary aged 120

  Expected value derived from the authority

  The terminal row. A divisor of 1.0 is what makes every lifetime schedule terminate.

  Divisor for 2026

  1.0

  How this was worked out: Treas. Reg. 1.401(a)(9)-9(b), Table 1, terminal row '120 and over' is 1.0. Age 120 is looked up rather than age 119, because the individual attains 120 in the relevant calendar year and the table is read at the attained age. A divisor of 1.0 means the year's minimum is the opening balance divided by 1.0, which is the whole balance, so a recalculated lifetime schedule reaching this row empties the account in that year rather than running forever. The floor is 1.0 and never zero or negative, which is what makes termination provable rather than hopeful.

  Technical details

  Case

  age-120-floor

  Inputs

  {"kind":"divisor","attainedAge":120,"method":"tableLookup"}

  Expected

  {"kind":"divisor","year":2026,"divisor":1}

• A beneficiary aged 121

  Expected value derived from the authority

  Past the end of the table. Clamped, never extrapolated and never an error.

  Divisor for 2026

  1.0

  How this was worked out: Treas. Reg. 1.401(a)(9)-9(b), Table 1's last row is '120 and over', so 121 is inside the published row rather than off the end of the table. Age 121 clamps to the key 120 and reads 1.0. Extrapolating past 119 by the table's own decrements would give a value below 1.0 and eventually below zero, which is the arithmetic a schedule must never be built on.

  Technical details

  Case

  age-121-clamps-to-120

  Inputs

  {"kind":"divisor","attainedAge":121,"method":"tableLookup"}

  Expected

  {"kind":"divisor","year":2026,"divisor":1}

• a surviving spouse, born 4 July 1942, of an owner born 15 March 1940 who died 20 August 2018

  Expected value derived from the authority

  Era A spouse who retitled the IRA as their own. Hands to Door 1.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Hands to Door 1's owner math, and says so plainly

  How this was worked out: Era: the owner died 2018-08-20, before 1 January 2020, so section 401(a)(9)(H) never applied and the era is preSecure. Relationship: surviving spouse, who has already treated the IRA as their own, which Treas. Reg. 1.408-8(c)(1) permits where the spouse is sole beneficiary with an unlimited right of withdrawal. That election makes the spouse the owner, so the owner math of Door 1 governs and no beneficiary schedule is computed. RBD: the owner was born 1940-03-15, which is before 1 July 1949, so the applicable age is 70 and a half under Treas. Reg. 1.401(a)(9)-2(b)(2)(ii); born March 1940, the owner attains age 70 and a half in September 2010, within calendar 2010, giving a required beginning date of 1 April 2011. Death in 2018 is therefore on or after the RBD, but row A1 carries rbd 'either' because the treat-as-own election makes the owner's date of death irrelevant to the schedule.

  Technical details

  Case

  row-a1-spouse-treated-as-own

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":true,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1940-03-15","ownerDeathDate":"2018-08-20","beneficiaryBirthDate":"1942-07-04","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"A1"}

• a surviving spouse, born 30 June 1950, of an owner born 10 February 1948 who died 15 January 2019

  Expected value derived from the authority

  Era A spouse who remains a beneficiary, owner died before the required beginning date.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Commencement deferred to the year the owner would have attained the applicable age, then recalculated annually

  How this was worked out: Era: death 2019-01-15 is before 1 January 2020, so preSecure. Relationship: surviving spouse who has NOT treated the IRA as their own, so the inherited-spouse rules apply rather than Door 1. RBD: born 1948-02-10, before 1 July 1949, so the applicable age is 70 and a half under Treas. Reg. 1.401(a)(9)-2(b)(2)(ii). February 1948 plus 70 years and 6 months is August 2018, so attainment is calendar 2018 and the required beginning date is 1 April 2019. Death on 15 January 2019 is BEFORE 1 April 2019, so the position is 'before', which is the case the spec calls out: a distribution was already owed for 2018 and yet the death is a before-RBD death. Commencement may then be delayed under Treas. Reg. 1.401(a)(9)-3(d) and the spouse's life expectancy is redetermined annually under Treas. Reg. 1.401(a)(9)-5(d)(3)(iv). Row A2. The owner's birth date was chosen before 1 July 1949 deliberately, so that the spec's '70 and a half' wording and the regulation's current 'applicable age' wording give the same year; see the report's divergence section.

  Technical details

  Case

  row-a2-spouse-beneficiary-before-rbd

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1948-02-10","ownerDeathDate":"2019-01-15","beneficiaryBirthDate":"1950-06-30","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"A2"}

• a surviving spouse, born 12 September 1943, of an owner born 15 March 1940 who died 20 August 2018

  Expected value derived from the authority

  Era A spouse who remains a beneficiary, owner died on or after the required beginning date.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Greater-of denominator

  How this was worked out: Era: death 2018-08-20, before 2020, so preSecure. Relationship: surviving spouse who has not treated the IRA as their own. RBD: born 1940-03-15, before 1 July 1949, applicable age 70 and a half, attained within calendar 2010, so the required beginning date is 1 April 2011 and a 2018 death is on or after it. Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) then makes the applicable denominator the greater of the beneficiary's and the owner's remaining life expectancies, which is the cross-cutting greater-of rule. Row A3.

  Technical details

  Case

  row-a3-spouse-beneficiary-on-or-after-rbd

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1940-03-15","ownerDeathDate":"2018-08-20","beneficiaryBirthDate":"1943-09-12","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"A3"}

• another individual, born 1 March 1985, of an owner born 20 May 1955 who died 10 April 2018

  Expected value derived from the authority

  Era A non-spouse designated beneficiary, owner died before the required beginning date.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Fixed term reduced by one, anchored at the year after death, with the 2022 reset

  How this was worked out: Era: death 2018-04-10, before 2020, so preSecure. Relationship: an unrelated individual, not a spouse. EDB category: Treas. Reg. 1.401(a)(9)-4(e)(1)(vi) makes ANY designated beneficiary of an employee who died before the section 401(a)(9)(H) effective date an eligible designated beneficiary, so the ten-year rule cannot reach this case and no separate EDB test is needed. RBD: born 1955-05-20, so not the pre-July-1949 cohort; the applicable age is 73 under IRC 401(a)(9)(C)(v), attained in 1955 plus 73 equals 2028, giving a required beginning date of 1 April 2029. Death in 2018 is far before it. Row A4, fixed term reduced by one anchored at the year after death per Treas. Reg. 1.401(a)(9)-5(d)(3)(iii), with the 2022 reset of Treas. Reg. 1.401(a)(9)-9(f)(2) applying because the anchor precedes 2022.

  Technical details

  Case

  row-a4-non-spouse-before-rbd

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1955-05-20","ownerDeathDate":"2018-04-10","beneficiaryBirthDate":"1985-03-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"A4"}

• another individual, born 20 January 1944, of an owner born 10 March 1939 who died 15 June 2019

  Expected value derived from the authority

  The regulation's own 2022-reset example, classified. Era A, non-spouse, death on or after the RBD.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Greater-of denominator, with the 2022 reset applied to the beneficiary's term

  How this was worked out: These are the facts of the example at Treas. Reg. 1.401(a)(9)-9(f)(2)(ii)(B): the owner dies at 80 in 2019 and the non-spouse designated beneficiary is 75 in the year of death. Encoded as an owner born 1939-03-10 who dies 2019-06-15 aged 80, and a beneficiary born 1944-01-20 who is 75 on the date of death and 76 in 2020. Era: 2019, so preSecure. Relationship: non-spouse individual. EDB: automatic under Treas. Reg. 1.401(a)(9)-4(e)(1)(vi) for a pre-effective-date death. RBD: born 1939-03-10, before 1 July 1949, applicable age 70 and a half, attained September 2009, so the required beginning date is 1 April 2010 and a 2019 death is on or after it. Row A5, greater-of with the 2022 reset applied to the beneficiary's term, which is the divisor pinned by reset-2022-regulation-example.

  Technical details

  Case

  row-a5-non-spouse-on-or-after-rbd

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1939-03-10","ownerDeathDate":"2019-06-15","beneficiaryBirthDate":"1944-01-20","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"A5"}

• a surviving spouse, born 22 March 1954, of an owner born 15 January 1952 who died 10 May 2024

  Expected value derived from the authority

  Era B spouse who retitled the IRA as their own. Hands to Door 1, and the expectation is the classification only, never a schedule.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Hands to Door 1's owner math, and says so plainly

  How this was worked out: Era: death 2024-05-10, on or after 1 January 2020, so secure. Relationship: surviving spouse who has already treated the IRA as their own under Treas. Reg. 1.408-8(c)(1). Once that election is made the spouse is the owner, so the owner math of Door 1 governs, the beneficiary tables are not reached, and the outcome is a hand-off rather than an inherited schedule. RBD position: the owner was born 1952-01-15, applicable age 73 under IRC 401(a)(9)(C)(v), attained 2025, required beginning date 1 April 2026, so the 2024 death is before the RBD; row B1 carries rbd 'either' because the election makes the position immaterial to the outcome.

  Technical details

  Case

  spouse-treated-as-own

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":true,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1952-01-15","ownerDeathDate":"2024-05-10","beneficiaryBirthDate":"1954-03-22","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B1"}

• a surviving spouse, born 30 November 1962, of an owner born 5 August 1960 who died 1 March 2024

  Expected value derived from the authority

  Era B spouse who remains a beneficiary. The inherited-spouse schedule, deferred to the owner's applicable-age year.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Deferred to the year the owner would have reached applicable age, then recalculated annually

  How this was worked out: Era: death 2024-03-01, so secure. Relationship: surviving spouse who has NOT treated the IRA as their own, so Treas. Reg. 1.401(a)(9)-3(d) and 1.401(a)(9)-5(d)(3)(iv) govern rather than Door 1. RBD: the owner was born 1960-08-05, so the applicable age is 75 under IRC 401(a)(9)(C)(v), attained 1960 plus 75 equals 2035, giving a required beginning date of 1 April 2036. The 2024 death is before it. Row B2: commencement may be delayed until the end of the calendar year in which the owner would have attained the applicable age, and the spouse's life expectancy is then redetermined annually rather than reduced by one.

  Technical details

  Case

  spouse-not-yet-treated-as-own

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1960-08-05","ownerDeathDate":"2024-03-01","beneficiaryBirthDate":"1962-11-30","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B2"}

• a surviving spouse, born 14 February 1950, of an owner born 12 September 1948 who died 4 July 2022

  Expected value derived from the authority

  Era B spouse who remains a beneficiary, owner died on or after the required beginning date.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Greater-of denominator

  How this was worked out: Era: death 2022-07-04, so secure. Relationship: surviving spouse, not treated as own. RBD: the owner was born 1948-09-12, before 1 July 1949, so the applicable age is 70 and a half. September 1948 plus 70 years and 6 months is March 2019, so attainment is calendar 2019 and the required beginning date is 1 April 2020. Death on 4 July 2022 is on or after it. Note the birth month matters here: a birth in the second half of the year pushes the 70-and-a-half attainment into the FOLLOWING calendar year, which is why 2019 rather than 2018 is the attainment year. Row B3, greater-of under Treas. Reg. 1.401(a)(9)-5(d)(1)(ii).

  Technical details

  Case

  row-b3-spouse-beneficiary-on-or-after-rbd

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1948-09-12","ownerDeathDate":"2022-07-04","beneficiaryBirthDate":"1950-02-14","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B3"}

• another individual, born 15 April 1990, of an owner born 1 June 1955 who died 20 February 2024

  Expected value derived from the authority

  Era B non-spouse who is not an eligible designated beneficiary, owner died before the required beginning date. The pure ten-year rule.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  No annual minimum; account empty by 31 December of year 10

  How this was worked out: Era: death 2024-02-20, so secure. Relationship: unrelated individual. EDB: none of the categories at Treas. Reg. 1.401(a)(9)-4(e)(1) is met. Not a spouse; not a child of the owner; no disability or chronic illness attested as of the date of death; and the ten-years-younger test of Treas. Reg. 1.401(a)(9)-4(e)(6) fails because the owner was born 1955-06-01 and a beneficiary is not more than 10 years younger only if born on or before 1965-06-01, whereas this beneficiary was born 1990-04-15. RBD: born 1955-06-01, applicable age 73, attained 2028, required beginning date 1 April 2029, so the 2024 death is before it. Row B4: no annual minimum, and the entire interest must be distributed by the end of the calendar year containing the tenth anniversary of the death, per Treas. Reg. 1.401(a)(9)-5(e)(2), which is 2034.

  Technical details

  Case

  row-b4-non-edb-before-rbd

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"tenYear","ownerBirthDate":"1955-06-01","ownerDeathDate":"2024-02-20","beneficiaryBirthDate":"1990-04-15","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B4"}

• another individual, born 1 January 1985, of an owner born 10 May 1948 who died 1 September 2023

  Expected value derived from the authority

  Era B non-EDB, owner died on or after the required beginning date. Annual minimums AND the ten-year deadline, which is the Schwab failure mode this door exists to prevent.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Annual minimum on the greater-of denominator and empty by year 10

  How this was worked out: Era: death 2023-09-01, so secure. Relationship: unrelated individual. EDB: none. The owner was born 1948-05-10, so under Treas. Reg. 1.401(a)(9)-4(e)(6) a beneficiary is not more than 10 years younger only if born on or before 1958-05-10; this beneficiary was born 1985-01-01 and so is more than 10 years younger. RBD: born 1948-05-10, before 1 July 1949, applicable age 70 and a half, attained November 2018, so calendar 2018, required beginning date 1 April 2019; the 2023 death is on or after it. Row B5: Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) supplies an annual minimum on the greater-of denominator AND Treas. Reg. 1.401(a)(9)-5(e)(2) requires the account emptied by the end of 2033. Both apply; neither replaces the other.

  Technical details

  Case

  row-b5-non-edb-on-or-after-rbd

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"tenYear","ownerBirthDate":"1948-05-10","ownerDeathDate":"2023-09-01","beneficiaryBirthDate":"1985-01-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B5"}

• another individual, born 1 October 1963, of an owner born 1 October 1953 who died 1 June 2026

  Expected value derived from the authority

  A beneficiary exactly ten years younger to the day is an eligible designated beneficiary.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Lifetime, reduced by one

  How this was worked out: Treas. Reg. 1.401(a)(9)-4(e)(6) states the example directly: if an employee's date of birth is October 1, 1953, the beneficiary is not more than 10 years younger if born on or before October 1, 1963. This beneficiary was born on that exact day, so the category is met and the beneficiary is an EDB. Era: death 2026-06-01, so secure. RBD, computed by hand: born 1953-10-01, not the pre-July-1949 cohort, applicable age 73 under IRC 401(a)(9)(C)(v), attained 1953 plus 73 equals 2026, so the required beginning date is 1 April 2027. Death on 1 June 2026 is BEFORE 1 April 2027. The row is therefore B6, lifetime reduced by one, and NOT B7. The Task 2 brief printed B7 for this case; the arithmetic above is why the fixture says B6. See the report's corrections section. The governingMethod field is deliberately absent because the owner died in the current year, which is when the spec's tree does not ask that question.

  Technical details

  Case

  ten-years-younger-boundary-eligible

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","ownerBirthDate":"1953-10-01","ownerDeathDate":"2026-06-01","beneficiaryBirthDate":"1963-10-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B6"}

• another individual, born 2 October 1963, of an owner born 1 October 1953 who died 1 June 2026

  Expected value derived from the authority

  One day younger and the same person is not an eligible designated beneficiary at all.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  No annual minimum; account empty by 31 December of year 10

  How this was worked out: The same example at Treas. Reg. 1.401(a)(9)-4(e)(6), one day the other side of its stated boundary: a beneficiary born October 2, 1963 IS more than 10 years younger than an owner born October 1, 1953, so no eligible-designated-beneficiary category applies and the ten-year rule governs. Era: death 2026-06-01, so secure. RBD, computed by hand: applicable age 73 for a 1953 birth, attained 2026, required beginning date 1 April 2027, so a 1 June 2026 death is BEFORE the RBD. The row is therefore B4, not B5 as the Task 2 brief printed. One day of the beneficiary's birth date moves the case from B6 to B4, which is the whole point of the pair.

  Technical details

  Case

  ten-years-younger-boundary-not-eligible

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","ownerBirthDate":"1953-10-01","ownerDeathDate":"2026-06-01","beneficiaryBirthDate":"1963-10-02","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B4"}

• another individual, born 1 October 1959, of an owner born 1 October 1949 who died 1 June 2024

  Expected value derived from the authority

  The same day-precise boundary, on the other side of the required beginning date, so both ten-years-younger branches are testable.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Lifetime, on the greater-of denominator

  How this was worked out: Treas. Reg. 1.401(a)(9)-4(e)(6) applied to a different pair of dates chosen so the RBD has passed: the owner was born 1949-10-01 and the beneficiary 1959-10-01, exactly ten years to the day, so the beneficiary is not more than 10 years younger and is an EDB. RBD: born October 1949, which is NOT the pre-1 July 1949 cohort, so the applicable age is 72 under IRC 401(a)(9)(C)(v), attained 1949 plus 72 equals 2021, and the required beginning date is 1 April 2022. Death 2024-06-01 is on or after it. Era secure. Row B7, lifetime on the greater-of denominator, because an EDB is still a designated beneficiary and Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) reaches every after-RBD branch and not only the ten-year one.

  Technical details

  Case

  ten-years-younger-boundary-eligible-on-or-after-rbd

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1949-10-01","ownerDeathDate":"2024-06-01","beneficiaryBirthDate":"1959-10-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B7"}

• another individual, born 2 October 1959, of an owner born 1 October 1949 who died 1 June 2024

  Expected value derived from the authority

  One day the other side, with the RBD passed. B5 rather than B7.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Annual minimum on the greater-of denominator and empty by year 10

  How this was worked out: Identical to ten-years-younger-boundary-eligible-on-or-after-rbd except the beneficiary was born 1959-10-02. Treas. Reg. 1.401(a)(9)-4(e)(6) makes a beneficiary not more than 10 years younger only if born on or before 1959-10-01, so one day later fails the test and no EDB category applies. RBD: 1 April 2022 as derived there, and the 2024-06-01 death is on or after it. Era secure. Row B5: an annual minimum on the greater-of denominator alongside the ten-year deadline of the end of 2034, per Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) and 1.401(a)(9)-5(e)(2).

  Technical details

  Case

  ten-years-younger-boundary-not-eligible-on-or-after-rbd

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"tenYear","ownerBirthDate":"1949-10-01","ownerDeathDate":"2024-06-01","beneficiaryBirthDate":"1959-10-02","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B5"}

• a child of the owner, born 20 June 2010, of an owner born 10 April 1975 who died 15 August 2022

  Expected value derived from the authority

  A minor child of the owner, owner died before the required beginning date.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Reduced by one until 21, then annual distributions continue alongside the terminal deadline measured from reaching 21

  How this was worked out: Era: death 2022-08-15, so secure. Relationship: a child of the owner within section 152(f)(1). EDB: Treas. Reg. 1.401(a)(9)-4(e)(1)(ii) with the age of majority fixed at the 21st birthday by Treas. Reg. 1.401(a)(9)-4(e)(3). The child was born 2010-06-20 and so had turned 12 on 2010-06-20 plus 12 years equals 2022-06-20, before the 15 August death, so the child is 12 and under 21 at the death. No other category is met: not a spouse, no disability or chronic illness attested as of the death, and more than 10 years younger. RBD: the owner was born 1975-04-10, applicable age 75, attained 2050, required beginning date 1 April 2051, so the 2022 death is before it. Row B8.

  Technical details

  Case

  row-b8-minor-child-before-rbd

  Inputs

  {"relationship":"childOfOwner","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1975-04-10","ownerDeathDate":"2022-08-15","beneficiaryBirthDate":"2010-06-20","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B8"}

• a child of the owner, born 15 May 2012, of an owner born 5 March 1950 who died 10 September 2024

  Expected value derived from the authority

  A minor child of the owner, owner died on or after the required beginning date. Uncommon in life and exactly why the row exists.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Greater-of until 21, then annual distributions continue alongside the terminal deadline measured from 21

  How this was worked out: Era: death 2024-09-10, so secure. Relationship: a child of the owner. EDB: minor child under Treas. Reg. 1.401(a)(9)-4(e)(1)(ii); the child was born 2012-05-15 and turned 12 on 2024-05-15, so is 12 at the September death and under the 21st-birthday majority of Treas. Reg. 1.401(a)(9)-4(e)(3). RBD: the owner was born 1950-03-05, which is not the pre-1 July 1949 cohort, so the applicable age is 72 under IRC 401(a)(9)(C)(v), attained 1950 plus 72 equals 2022, and the required beginning date is 1 April 2023. Death on 10 September 2024 is on or after it. Row B9. Reaching this row requires an owner past their RBD with a child under 21, which means a child born when the owner was about 62; the combination is uncommon, and a matrix that omitted it would silently push these readers onto B8's before-RBD arithmetic.

  Technical details

  Case

  row-b9-minor-child-on-or-after-rbd

  Inputs

  {"relationship":"childOfOwner","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1950-03-05","ownerDeathDate":"2024-09-10","beneficiaryBirthDate":"2012-05-15","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B9"}

• another individual, born 20 June 2010, of an owner born 10 April 1975 who died 15 August 2022

  Expected value derived from the authority

  Identical facts to row-b8-minor-child-before-rbd, but the minor is a grandchild. Not an EDB.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  No annual minimum; account empty by 31 December of year 10

  How this was worked out: Every fact is the same as row-b8-minor-child-before-rbd except the relationship. Treas. Reg. 1.401(a)(9)-4(e)(1)(ii) confers the minor-child category only on a child of the EMPLOYEE within the meaning of section 152(f)(1). A grandchild is not that, and no other category at 1.401(a)(9)-4(e)(1) is met: not a spouse, nothing attested as of the death, and more than 10 years younger than an owner born 1975-04-10, since the cutoff for that test is a birth on or before 1985-04-10. So this beneficiary is a plain designated beneficiary, the ten-year rule governs, and the death was before the required beginning date of 1 April 2051. Row B4, not B8. This is the distinction most tools get wrong: a minor is not enough, only a minor CHILD of the owner.

  Technical details

  Case

  minor-grandchild-not-edb

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"tenYear","ownerBirthDate":"1975-04-10","ownerDeathDate":"2022-08-15","beneficiaryBirthDate":"2010-06-20","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B4"}

• a child of the owner, born 10 May 2003, of an owner born 10 February 1948 who died 1 July 2022

  Expected value derived from the authority

  Example 1 at 1.401(a)(9)-4(e)(9)(i). A minor child of the owner who was also disabled as of the death remains an EDB past 21, so no age-21 flip ever happens.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Lifetime, on the greater-of denominator

  How this was worked out: Treas. Reg. 1.401(a)(9)-4(e)(9)(i), Example 1: the employee's child is the sole beneficiary, will not reach majority until 2024, the employee dies 1 July 2022 after the required beginning date, and the child is disabled within 1.401(a)(9)-4(e)(4) as of that date with documentation timely provided. The regulation's conclusion is that the child remains an eligible designated beneficiary after reaching majority in 2024, the plan is NOT required to distribute by the end of 2034 under 1.401(a)(9)-5(e)(4), and life expectancy payments may continue for life. Encoded with an owner born 1948-02-10 so the RBD position matches the example: before 1 July 1949, so applicable age 70 and a half, August 2018 attainment, required beginning date 1 April 2019, and the 1 July 2022 death is on or after it. The child was born 2003-05-10 and so turns 21 on 2024-05-10, matching the example's 2024 majority. Precedence: the disabled category outranks minor child of the owner because it survives majority, so the governing category is disabled and the row is B7, lifetime on the greater-of denominator, with no terminal deadline, terminalDeadlineFrom none.

  Technical details

  Case

  disabled-minor-child-stays-edb

  Inputs

  {"relationship":"childOfOwner","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1948-02-10","ownerDeathDate":"2022-07-01","beneficiaryBirthDate":"2003-05-10","accountType":"traditional","edbStatus":"disabled"}

  Expected

  {"kind":"classified","rowId":"B7"}

• a child of the owner, born 10 May 2003, of an owner born 10 February 1948 who died 1 July 2022

  Expected value derived from the authority

  Examples 2 and 3 at 1.401(a)(9)-4(e)(9)(ii) and (iii) collapse to this single engine case, because TreeAnswers attests only status as of the death and has no field for documentation timeliness.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Greater-of until 21, then annual distributions continue alongside the terminal deadline measured from 21

  How this was worked out: Treas. Reg. 1.401(a)(9)-4(e)(9) prints two distinct negative controls on the facts of Example 1. Example 2, at 1.401(a)(9)-4(e)(9)(ii): the child is disabled as of the death, but the documentation required by 1.401(a)(9)-4(e)(7) is not timely satisfied, so under 1.401(a)(9)-4(e)(4) the disabled category is never established. Example 3, at 1.401(a)(9)-4(e)(9)(iii): the child is not disabled as of the death at all, becoming disabled only in 2023, and 1.401(a)(9)-4(e)(1) and (e)(4) both test the category 'as of the date of the employee's death', so the later onset does not qualify either. Both examples reach the identical regulatory conclusion: the disabled category was never established as of the death, the child ceases to be an eligible designated beneficiary on reaching majority in 2024, and the plan is required to distribute by the end of 2034. TreeAnswers has one field for this, edbStatus, a tri-state attestation of status AS OF THE DEATH with no separate answer for whether disability documentation was timely filed or for when disability arose. A reader in either fact pattern, untimely documentation or post-death onset, answers edbStatus 'neither', and the two examples become one engine case rather than two: nothing downstream of the tree can tell them apart, so encoding them as separate goldens would have looked like two independent checks while testing the same branch twice. The remaining category is minor child of the owner, the death is on or after the required beginning date of 1 April 2019 as derived in disabled-minor-child-stays-edb, and the era is secure, so the row is B9. This is still a negative control against disabled-minor-child-stays-edb: the two differ in one attested fact and land on different rows with different terminal treatment.

  Technical details

  Case

  disabled-after-death-does-not-count

  Inputs

  {"relationship":"childOfOwner","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1948-02-10","ownerDeathDate":"2022-07-01","beneficiaryBirthDate":"2003-05-10","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B9"}

• a child of the owner, born 8 July 1990, of an owner born 15 January 1960 who died 20 March 2024

  Expected value derived from the authority

  An adult child of the owner who is disabled as of the death. Lifetime treatment, because the disability qualifies and being a child no longer does.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Lifetime, reduced by one

  How this was worked out: Era: death 2024-03-20, so secure. Relationship: a child of the owner, but born 1990-07-08 and so 33 at the death, past the 21st-birthday age of majority at Treas. Reg. 1.401(a)(9)-4(e)(3), which means the minor-child category at 1.401(a)(9)-4(e)(1)(ii) is unavailable. The disabled category at 1.401(a)(9)-4(e)(1)(iii) and (e)(4)(ii), attested as of the date of death, is what makes this beneficiary an EDB, and it is not age-limited. RBD: the owner was born 1960-01-15, applicable age 75, attained 2035, required beginning date 1 April 2036, so the 2024 death is before it. Row B6, lifetime reduced by one, with no terminal deadline. Being a child of the owner confers nothing here; strip the disability and the same person falls to B4.

  Technical details

  Case

  adult-disabled-child

  Inputs

  {"relationship":"childOfOwner","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1960-01-15","ownerDeathDate":"2024-03-20","beneficiaryBirthDate":"1990-07-08","accountType":"traditional","edbStatus":"disabled"}

  Expected

  {"kind":"classified","rowId":"B6"}

• a child of the owner, born 8 July 1990, of an owner born 15 January 1960 who died 20 March 2024

  Expected value derived from the authority

  The same adult child with no qualifying status. Ordinary ten-year rule. Pins that being a child of the owner confers nothing after 21.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  No annual minimum; account empty by 31 December of year 10

  How this was worked out: Identical to adult-disabled-child except edbStatus is 'neither'. The child was born 1990-07-08 and is 33 at the 2024-03-20 death, so the minor-child category at Treas. Reg. 1.401(a)(9)-4(e)(1)(ii) is unavailable under the 21st-birthday majority of 1.401(a)(9)-4(e)(3). The ten-years-younger test at 1.401(a)(9)-4(e)(6) also fails: the owner was born 1960-01-15, so the cutoff is a birth on or before 1970-01-15. No category is met, so this is a plain designated beneficiary under the ten-year rule. The death was before the required beginning date of 1 April 2036, and the era is secure. Row B4. The pair adult-disabled-child and this case differ in one attested fact and separate a lifetime schedule from a ten-year deadline.

  Technical details

  Case

  adult-child-not-otherwise-edb

  Inputs

  {"relationship":"childOfOwner","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"tenYear","ownerBirthDate":"1960-01-15","ownerDeathDate":"2024-03-20","beneficiaryBirthDate":"1990-07-08","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B4"}

• another individual, born 1 January 1985, of an owner born 10 May 1944 who died 1 August 2024

  Expected value derived from the authority

  A Roth owner who died at 80. Treated as dying before the required beginning date, so greater-of never applies.

  Account

  Roth IRA

  The rule that governs

  No annual minimum; account empty by 31 December of year 10

  How this was worked out: Treas. Reg. 1.408A-6, A-14(b), under IRC 408A(c)(5): 'The minimum distribution rules apply to the Roth IRA as though the Roth IRA owner died before his or her required beginning date.' The owner was born 1944-05-10 and died 2024-08-01 aged 80. On the traditional arithmetic this would be an on-or-after death: born before 1 July 1949, applicable age 70 and a half, attained November 2014, required beginning date 1 April 2015, and the 2024 death is nine years after it, which would give row B5 with a greater-of annual minimum. The Roth rule overrides that and forces the before-RBD variant. Era secure, beneficiary an unrelated individual born 1985-01-01 who is more than 10 years younger than the 1944-05-10 cutoff date of 1954-05-10 and attests neither status, so not an EDB. Row B4: no annual minimum, ten-year deadline at the end of 2034. The case is chosen so that the Roth rule is load-bearing: remove it and the row moves to B5.

  Technical details

  Case

  roth-owner-deemed-before-rbd

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"tenYear","ownerBirthDate":"1944-05-10","ownerDeathDate":"2024-08-01","beneficiaryBirthDate":"1985-01-01","accountType":"roth","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B4"}

• another individual, born 3 March 1975, of an owner born 20 February 1940 who died 15 June 2018

  Expected value derived from the authority

  A Roth case in era A, so the Roth rule and the era rule compose.

  Account

  Roth IRA

  The rule that governs

  Fixed term reduced by one, anchored at the year after death, with the 2022 reset

  How this was worked out: Treas. Reg. 1.408A-6, A-14(b) treats the Roth owner as having died before the required beginning date. Era: death 2018-06-15, before 1 January 2020, so preSecure, and Treas. Reg. 1.401(a)(9)-4(e)(1)(vi) makes the designated beneficiary an eligible designated beneficiary automatically. On the traditional arithmetic the owner, born 1940-02-20, is in the pre-1 July 1949 cohort with applicable age 70 and a half attained August 2010, giving a required beginning date of 1 April 2011 and an on-or-after death, which would be row A5 with a greater-of denominator. The Roth rule forces the before-RBD variant, so the row is A4: fixed term reduced by one, anchored at the beneficiary's age in 2019, the year after death, with the 2022 reset of Treas. Reg. 1.401(a)(9)-9(f)(2) applying because the anchor precedes 2022. Both rules are load-bearing: drop the Roth rule and it is A5, move the death to 2020 and it is B4.

  Technical details

  Case

  roth-pre-2020-death

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1940-02-20","ownerDeathDate":"2018-06-15","beneficiaryBirthDate":"1975-03-03","accountType":"roth","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"A4"}

• another individual, born 1 January 1985, of an owner born 15 June 1950 who died 31 March 2023

  Expected value derived from the authority

  Death on 31 March of the required beginning date year. Before the RBD by one day.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  No annual minimum; account empty by 31 December of year 10

  How this was worked out: Treas. Reg. 1.401(a)(9)-2(b)(1) with IRC 401(a)(9)(C)(v): the owner was born 1950-06-15, not the pre-1 July 1949 cohort, so the applicable age is 72, attained 1950 plus 72 equals 2022, and the required beginning date is 1 April 2023. Death on 31 March 2023 is one day before it, so the position is 'before'. This is the case the spec singles out: a distribution was already owed for the 2022 distribution calendar year and the owner may even have taken it, and the death is still a before-RBD death. Era secure. The beneficiary, born 1985-01-01, is more than 10 years younger than the 1960-06-15 cutoff and attests neither status, so not an EDB. Row B4, no annual minimum.

  Technical details

  Case

  rbd-boundary-day-before

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"tenYear","ownerBirthDate":"1950-06-15","ownerDeathDate":"2023-03-31","beneficiaryBirthDate":"1985-01-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B4"}

• another individual, born 1 January 1985, of an owner born 15 June 1950 who died 1 April 2023

  Expected value derived from the authority

  Death on 1 April itself. On or after, because the test is inclusive.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Annual minimum on the greater-of denominator and empty by year 10

  How this was worked out: Identical to rbd-boundary-day-before except the death is 2023-04-01. Treas. Reg. 1.401(a)(9)-2(b)(1) fixes the required beginning date at 1 April of the year following attainment of the applicable age, and death ON that date is death on or after it: the comparison is inclusive, not strict. One day moves the case from B4 to B5, which adds an annual minimum on the greater-of denominator under Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) on top of the same ten-year deadline. Row B5.

  Technical details

  Case

  rbd-boundary-on-the-day

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"tenYear","ownerBirthDate":"1950-06-15","ownerDeathDate":"2023-04-01","beneficiaryBirthDate":"1985-01-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B5"}

• another individual, born 1 January 1985, of an owner born 15 June 1950 who died 2 April 2023

  Expected value derived from the authority

  Death on 2 April. Plainly on or after, and the third leg of the one-day-apart triple.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Annual minimum on the greater-of denominator and empty by year 10

  How this was worked out: Identical to rbd-boundary-on-the-day except the death is 2023-04-02, one day past the required beginning date of 1 April 2023 derived under Treas. Reg. 1.401(a)(9)-2(b)(1) from a 1950-06-15 birth and an applicable age of 72. Row B5. The triple 31 March, 1 April, 2 April exists so that an off-by-one in the comparison operator, strict versus inclusive, cannot pass: a strict comparison would move only the middle case and only the middle case.

  Technical details

  Case

  rbd-boundary-day-after

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"tenYear","ownerBirthDate":"1950-06-15","ownerDeathDate":"2023-04-02","beneficiaryBirthDate":"1985-01-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B5"}

• a trust, born 1 January 1985, of an owner born 15 June 1950 who died 1 May 2023

  Expected value derived from the authority

  A trust beneficiary, see-through or not. Declined with the trust card, never a number.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: This account is left to a trust

  How this was worked out: Treas. Reg. 1.401(a)(9)-4(f) makes the beneficiaries of a see-through trust the designated beneficiaries only where the trust satisfies (f)(2), and 1.401(a)(9)-5(f) then determines the applicable denominator from the oldest of them, with further special rules at 1.401(a)(9)-4(g) for an applicable multi-beneficiary trust. Every one of those turns on the trust's own terms, which this calculator has not read and cannot read. The spec's declined table gives this its own card so that the outcome names what makes the case different rather than producing a plausible number. TreeAnswers now carries relationship 'trust' as its own member of the union, distinct from 'nonIndividual', so this case routes to the trust card without any field outside the interface.

  Technical details

  Case

  card-trust

  Inputs

  {"relationship":"trust","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1950-06-15","ownerDeathDate":"2023-05-01","beneficiaryBirthDate":"1985-01-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"trust"}

• an estate, a charity or another organisation, born 1 January 1985, of an owner born 15 June 1950 who died 1 May 2023

  Expected value derived from the authority

  An estate, a charity or another organisation. No life to measure.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: This account is left to an estate, a charity or another organisation

  How this was worked out: Treas. Reg. 1.401(a)(9)-4(a) limits designated beneficiaries to individuals, and 1.401(a)(9)-5(d)(1)(iii) makes the applicable denominator the EMPLOYEE's remaining life expectancy where there is no designated beneficiary, while 1.401(a)(9)-3(c)(5)(i)(A) applies the five-year rule where the death was before the required beginning date. Those are two different regimes turning on facts about a dead person rather than the reader, and v1 computes neither. The card names that and says what to ask for.

  Technical details

  Case

  card-entity

  Inputs

  {"relationship":"nonIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1950-06-15","ownerDeathDate":"2023-05-01","beneficiaryBirthDate":"1985-01-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"entity"}

• another individual, born 1 January 1985, of an owner born 15 June 1950 who died 1 May 2023

  Expected value derived from the authority

  Inherited from someone who had already inherited.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: You inherited this from someone who had already inherited it

  How this was worked out: Treas. Reg. 1.401(a)(9)-5(e)(3) sets a successor's outer limit at the calendar year containing the tenth anniversary of the FIRST beneficiary's death, and 1.401(a)(9)-5(d)(1) continues the denominator the first beneficiary was on rather than starting a new one. Both figures are facts about somebody else's account and somebody else's schedule, which the reader in front of this calculator does not have. Declined with the successor card, which states the continuation rule so the reader knows what to ask the custodian for.

  Technical details

  Case

  card-successor

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"priorBeneficiary","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1950-06-15","ownerDeathDate":"2023-05-01","beneficiaryBirthDate":"1985-01-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"successor"}

• another individual, born 1 January 1985, of an owner born 15 June 1950 who died 1 May 2023

  Expected value derived from the authority

  Multiple beneficiaries where separate accounts were not established by the deadline.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: This account has more than one beneficiary and was not split by the deadline

  How this was worked out: Treas. Reg. 1.401(a)(9)-5(f)(1)(i) determines the applicable denominator from the OLDEST designated beneficiary where separate accounts under 1.401(a)(9)-8(a) were not established, and 1.401(a)(9)-4(e)(2)(i) treats the employee as having no eligible designated beneficiary at all if any one of several is not an EDB. Both consequences depend on other people's dates of birth and statuses that this calculator has not collected, and either can change every schedule involved. Declined.

  Technical details

  Case

  card-unseparated

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"notSeparated","governingMethod":"lifeExpectancy","ownerBirthDate":"1950-06-15","ownerDeathDate":"2023-05-01","beneficiaryBirthDate":"1985-01-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"unseparatedSplit"}

• another individual, born 1 January 1985, of an owner born 15 June 1940 who died 1 May 2018

  Expected value derived from the authority

  Distribution under the five-year rule rather than life expectancy.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: We cannot tell which distribution method governs this account

  How this was worked out: Treas. Reg. 1.401(a)(9)-3(c)(2) is a deadline and not a schedule: the entire interest must be out by the end of the calendar year containing the fifth anniversary of the death, with the 2020 calendar year disregarded for a pre-2020 death. There is no divisor and no annual minimum to compute, so a tool that produced one would be inventing a requirement. The spec's declined table names this situation on the method-not-computable card, and v1 declines rather than rendering an empty schedule.

  Technical details

  Case

  card-method-not-computable

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"fiveYear","ownerBirthDate":"1940-06-15","ownerDeathDate":"2018-05-01","beneficiaryBirthDate":"1985-01-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"methodNotComputable"}

• another individual, born 1 January 1985, of an owner born 15 June 1950 who died 1 May 2023

  Expected value derived from the authority

  An annuitised contract. Defined benefit rules, not defined contribution ones.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: We cannot tell which distribution method governs this account

  How this was worked out: Treas. Reg. 1.401(a)(9)-5(a)(5)(ii) moves an account to the annuity rules of 1.401(a)(9)-6 for every calendar year after the year of purchase, so the account-balance-over-divisor arithmetic this door implements stops applying entirely. Payments are then governed by the contract's own terms. Declined with the method-not-computable card.

  Technical details

  Case

  card-method-not-computable-annuitised

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"annuitised","ownerBirthDate":"1950-06-15","ownerDeathDate":"2023-05-01","beneficiaryBirthDate":"1985-01-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"methodNotComputable"}

• another individual, born 1 January 1985, of an owner born 15 June 1950 who died 1 May 2025

  Expected value derived from the authority

  No method yet, because the election deadline has not arrived.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: We cannot tell which distribution method governs this account

  How this was worked out: Treas. Reg. 1.401(a)(9)-3(c)(5)(iii)(B) lets the election between the ten-year rule and the life expectancy rule run to the end of the earlier of the year the ten-year rule would require distribution and the year life expectancy payments would have to begin, and only then is it irrevocable. Before that date there is no method in force to compute, so any schedule shown would be a guess at an election the reader has not yet made. Declined.

  Technical details

  Case

  card-method-not-computable-not-yet-due

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"notYetDue","ownerBirthDate":"1950-06-15","ownerDeathDate":"2025-05-01","beneficiaryBirthDate":"1985-01-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"methodNotComputable"}

• another individual, born 1 January 1985, of an owner born 15 June 1950 who died 1 May 2023

  Expected value derived from the authority

  A reader who does not know which method governs. The single most important decline.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: We cannot tell which distribution method governs this account

  How this was worked out: Treas. Reg. 1.401(a)(9)-3(c)(5) makes the governing method a function of plan terms and an irrevocable election, neither of which is visible from withdrawal history: a beneficiary may have missed a required distribution, taken a voluntary one under no method at all, or had a custodian apply a method they never understood. Inferring the rule from observed withdrawals is the Schwab failure in a different costume, so an unknown method is declined rather than guessed.

  Technical details

  Case

  card-method-not-computable-unknown

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"unknown","ownerBirthDate":"1950-06-15","ownerDeathDate":"2023-05-01","beneficiaryBirthDate":"1985-01-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"methodNotComputable"}

• another individual, born 1 October 1959, of an owner born 1 October 1949 who died 1 June 2024

  Expected value derived from the authority

  An eligible designated beneficiary for whom the ten-year rule governs. Permitted by the regulation and not computed in v1.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: We cannot tell which distribution method governs this account

  How this was worked out: Treas. Reg. 1.401(a)(9)-3(c)(5)(ii) expressly permits a plan to specify that the ten-year rule applies to some or all employees who have an eligible designated beneficiary, and (c)(5)(iii) permits an election to the same effect. So an EDB can be under the ten-year rule, and when that happens neither the lifetime rows nor the non-EDB rows describe the case. Here the beneficiary IS an EDB, being born 1959-10-01 to an owner born 1949-10-01 and so not more than 10 years younger under 1.401(a)(9)-4(e)(6), yet the answers say the ten-year rule is what governs. The spec's declined table names exactly this on the method-not-computable card. Without the rule the same inputs would classify as B7 and produce a lifetime schedule that is not the schedule this account is on.

  Technical details

  Case

  card-method-not-computable-edb-under-ten-year

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"tenYear","ownerBirthDate":"1949-10-01","ownerDeathDate":"2024-06-01","beneficiaryBirthDate":"1959-10-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"methodNotComputable"}

• a surviving spouse, born 14 August 1957, of an owner born 20 April 1955 who died 1 May 2023

  Expected value derived from the authority

  The SECURE 2.0 surviving-spouse election. A decline for cause, with an authority.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: You are asking about the surviving spouse election under SECURE 2.0 section 327

  How this was worked out: Announcement 2026-7, Internal Revenue Bulletin 2026-11 page 697, 9 March 2026, delays the future final regulations amending Treas. Reg. 1.401(a)(9)-4, -5 and -6 that arise from the 2024 proposed regulations at 89 FR 58644, to a distribution calendar year beginning no earlier than six months after those final regulations publish, with taxpayers applying a reasonable good-faith interpretation in the interim. The operational rules for the section 327 election sit in those delayed amendments. The Announcement does NOT delay T.D. 10001, 89 FR 58886, so everything else this door computes remains settled law. Declined with the section 327 card, which cites the Announcement by name and date.

  Technical details

  Case

  card-section-327

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"electingSection327":true,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1955-04-20","ownerDeathDate":"2023-05-01","beneficiaryBirthDate":"1957-08-14","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"section327"}

• a surviving spouse, born 5 January 1966, of an owner born 15 June 1953 who died 20 November 2019

  Expected value derived from the authority

  A traditional spouse-remains-beneficiary case whose two candidate commencement years straddle 1 January 2025, so no single edition of the regulation settles the year.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: When your deferral must begin turns on an unsettled reading

  How this was worked out: CORRECTED 2026-08-26, inputs and ground both. The owner here was born 1964-03-10 and the derivation read that a pre-2020 death chose between a '70 and a half' reading and the amended 'applicable age' one. It does not. Treas. Reg. 1.401(a)(9)-1(d), eCFR title 26 at issue date 2026-08-24: 'This section and 1.401(a)(9)-2 through 1.401(a)(9)-9 apply for purposes of determining required minimum distributions for calendar years beginning on or after January 1, 2025. For earlier calendar years, the rules ... as those sections appeared in the April 1, 2023, edition of 26 CFR part 1 apply.' The edition is chosen by DISTRIBUTION CALENDAR YEAR and there is no carve-out keyed to the year of death, so a 1964 birth is settled and now computes. Owner born 1953-06-15 instead. Candidate one, the April 2023 edition: 1.401(a)(9)-3 A-3(b)(2) of that edition, read from the same API at issue date 2023-04-01, defers to 'The end of the calendar year in which the employee would have attained age 70 1/2'. June 1953 plus 70 years is June 2023, plus 6 months is December 2023, so calendar 2023. Candidate two, the current edition: 1.401(a)(9)-3(d) defers to 'the end of the calendar year in which the employee would have attained the applicable age', and 1.401(a)(9)-2(b)(2)(iv) gives an employee 'born on or after January 1, 1951, but before January 1, 1959' an applicable age of 73, so 1953 plus 73 is 2026. 2023 falls under the April 2023 edition and 2026 under the current one, so the two candidates straddle 1 January 2025 and neither edition governs both. Declined. Era: death 2019-11-20 is before 1 January 2020, so preSecure, and the spouse has not treated the IRA as their own.

  Technical details

  Case

  card-spouse-deferral-unsettled

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1953-06-15","ownerDeathDate":"2019-11-20","beneficiaryBirthDate":"1966-01-05","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"spouseDeferralUnsettled"}

• a surviving spouse, born 5 January 1966, of an owner born 31 December 1951 who died 20 November 2019

  Expected value derived from the authority

  One day BEFORE the straddle cohort opens. Both candidate commencement years fall under the April 2023 edition, so one edition settles both and the case computes.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Commencement deferred to the year the owner would have attained the applicable age, then recalculated annually

  How this was worked out: Owner born 1951-12-31. Candidate one, April 2023 edition, Treas. Reg. 1.401(a)(9)-3 A-3(b)(2), age 70 and a half: December 1951 plus 70 years is December 2021, plus 6 months is June 2022, so calendar 2022. Candidate two, current edition, 1.401(a)(9)-3(d) with 1.401(a)(9)-2(b)(2)(iv), which reaches an employee 'born on or after January 1, 1951, but before January 1, 1959' at applicable age 73: 1951 plus 73 is 2024. Both 2022 and 2024 are calendar years before 2025, so under 1.401(a)(9)-1(d) the April 2023 edition governs both and there is no straddle. Computed rather than declined. Row: era is preSecure because death 2019-11-20 precedes 1 January 2020; the required beginning date is 1 April of the year after applicable-age attainment, so 2025-04-01, and death on 2019-11-20 is before it, giving rbd position 'before' and row A2. Note for a later reader: the governing April 2023 edition names 2022 as this owner's deferral year while the engine's spouseDeferredCommencementYear returns the applicable-age year 2024. Both are before CURRENT_RMD_YEAR, and buildInheritedSchedule starts at CURRENT_RMD_YEAR, so no projected year is suppressed by the difference and no figure this calculator prints depends on it. This golden pins the row only.

  Technical details

  Case

  spouse-deferral-boundary-1951-12-31-computed

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1951-12-31","ownerDeathDate":"2019-11-20","beneficiaryBirthDate":"1966-01-05","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"A2"}

• a surviving spouse, born 5 January 1966, of an owner born 1 January 1952 who died 20 November 2019

  Expected value derived from the authority

  One day INTO the straddle cohort. The applicable-age year moves to 2025 while the 70 and a half year stays in 2022, so the two editions split the case.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: When your deferral must begin turns on an unsettled reading

  How this was worked out: Owner born 1952-01-01, one day later than the computed case above, and that one day moves the answer. Candidate one, April 2023 edition, age 70 and a half: January 1952 plus 70 years is January 2022, plus 6 months is July 2022, so calendar 2022, unchanged from a 1951-12-31 birth. Candidate two, current edition: Treas. Reg. 1.401(a)(9)-2(b)(2)(iv) gives applicable age 73 to a birth 'on or after January 1, 1951, but before January 1, 1959', so 1952 plus 73 is 2025. Under Treas. Reg. 1.401(a)(9)-1(d) the year 2022 falls to the April 2023 edition and 2025 to the current one, so the candidates straddle 1 January 2025 and no single edition settles the commencement year. Declined with the spouseDeferralUnsettled card. This is the lower boundary of the declined range, and it is the applicable-age year rather than the 70 and a half year that crosses here.

  Technical details

  Case

  spouse-deferral-boundary-1952-01-01-declined

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1952-01-01","ownerDeathDate":"2019-11-20","beneficiaryBirthDate":"1966-01-05","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"spouseDeferralUnsettled"}

• a surviving spouse, born 5 January 1966, of an owner born 30 June 1954 who died 20 November 2019

  Expected value derived from the authority

  The LAST day of the straddle cohort. The 70 and a half year is still 2024 and the applicable-age year is 2027.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: When your deferral must begin turns on an unsettled reading

  How this was worked out: Owner born 1954-06-30. Candidate one, April 2023 edition, age 70 and a half: June 1954 plus 70 years is June 2024, plus 6 months is December 2024, so calendar 2024, the last month that keeps this candidate under the April 2023 edition. Candidate two, current edition: Treas. Reg. 1.401(a)(9)-2(b)(2)(iv) applicable age 73, so 1954 plus 73 is 2027. 2024 falls under the April 2023 edition and 2027 under the current one, so the candidates straddle 1 January 2025. Declined. Note that the crossing here is the reverse of the 1952 boundary: it is the 70 and a half candidate that sits on the earlier side, and one more day of birth date pushes it over.

  Technical details

  Case

  spouse-deferral-boundary-1954-06-30-declined

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1954-06-30","ownerDeathDate":"2019-11-20","beneficiaryBirthDate":"1966-01-05","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"spouseDeferralUnsettled"}

• a surviving spouse, born 5 January 1966, of an owner born 1 July 1954 who died 20 November 2019

  Expected value derived from the authority

  One day AFTER the straddle cohort closes. The 70 and a half year crosses into 2025, so both candidates now sit under the current edition.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Commencement deferred to the year the owner would have attained the applicable age, then recalculated annually

  How this was worked out: Owner born 1954-07-01, one day later than the declined case above. Candidate one, April 2023 edition, age 70 and a half: July 1954 plus 70 years is July 2024, plus 6 months is January 2025, so calendar 2025 rather than 2024. That single day is what moves this candidate across 1 January 2025. Candidate two, current edition: applicable age 73 under Treas. Reg. 1.401(a)(9)-2(b)(2)(iv), so 1954 plus 73 is 2027. Both 2025 and 2027 are calendar years beginning on or after 1 January 2025, so under Treas. Reg. 1.401(a)(9)-1(d) the current edition governs both and 1.401(a)(9)-3(d)'s applicable-age deferral is the only reading in play. No straddle, so computed. Row: preSecure era from a 2019-11-20 death; required beginning date 1 April 2028, which the death precedes, so rbd position 'before' and row A2. This is the case the retired predicate got most conspicuously wrong: it declined every owner born on or after 1 July 1949 and so declined this one, although nothing about it is unsettled.

  Technical details

  Case

  spouse-deferral-boundary-1954-07-01-computed

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1954-07-01","ownerDeathDate":"2019-11-20","beneficiaryBirthDate":"1966-01-05","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"A2"}

• a surviving spouse, born 5 January 1966, of an owner born 20 May 1959 who died 20 November 2019

  Expected value derived from the authority

  Calendar 1959, the cohort whose paragraph the regulation reserves. Computed on the proposed age of 73 and shown the reserved paragraph, rather than declined.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Commencement deferred to the year the owner would have attained the applicable age, then recalculated annually

  How this was worked out: Owner born 1959-05-20, spouse remains a beneficiary of a traditional IRA, owner died 2019-11-20. DERIVED FROM THE AUTHORITY, NOT THE ENGINE, and the chain is long on purpose because this cohort is the one the regulation does not answer. Treas. Reg. 1.401(a)(9)-2(b)(2), eCFR title 26 at issue date 2026-08-25, sets the applicable age by cohort: (iv) reaches an employee 'born on or after January 1, 1951, but before January 1, 1959' at age 73, (v) is '[Reserved]', and (vi) reaches one 'born on or after January 1, 1960' at age 75. A birth on 20 May 1959 falls in the gap. T.D. 10001, 89 FR 58886 at 58891 footnote 7, states why it is blank: section 107 of SECURE 2.0 'includes an ambiguity relating to the definition of applicable age for employees born in 1959 (section 401(a)(9)(C)(v) provides that the applicable age for those employees is both 73 and 75)', and the resolution was moved to REG-103529-23. That proposed rule, 89 FR 58644 with its regulatory text at 58650, would add '(v) Employees born in 1959. In the case of an employee born in 1959, the applicable age is age 73.' It was still a PROPOSED rule on 2026-08-26, checked against the Federal Register documents API for the docket. John's decision of that date: compute on 73 and disclose the proposal rather than decline. So the applicable age is 73, attainment is 1959 plus 73 which is 2032, and the required beginning date under Treas. Reg. 1.401(a)(9)-2(b)(1) is 1 April 2033. The death on 20 November 2019 precedes that date, so the owner died BEFORE the required beginning date. 401(a)(9)(H) reaches only deaths after 31 December 2019, so the pre-SECURE era governs. Spouse beneficiary, pre-SECURE, before the required beginning date is row A2: commencement deferred under Treas. Reg. 1.401(a)(9)-3(d) to the end of 2032, then recalculated annually under -5(d)(3)(iv). NOT a straddle, and the straddle test does not reach it: the applicable-age year 2032 and the 70-and-a-half year 2029 both fall on or after 1 January 2025, so one edition governs both under 1.401(a)(9)-1(d). This case expected a decline from stage 3b until 2026-08-26 and is the reason it no longer does. It must also carry the applicableAge1959 notice, which A2 is one of only two rows to take.

  Technical details

  Case

  spouse-deferral-1959-reserved

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1959-05-20","ownerDeathDate":"2019-11-20","beneficiaryBirthDate":"1966-01-05","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"A2"}

• a surviving spouse, born 5 January 1966, of an owner born 20 May 1960 who died 20 November 2019

  Expected value derived from the authority

  The twin of the reserved-1959 case, one calendar year later, where paragraph (vi) does name an applicable age.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Commencement deferred to the year the owner would have attained the applicable age, then recalculated annually

  How this was worked out: Owner born 1960-05-20, the same day of the year as the reserved case above, so the birth YEAR is the only thing that can move the answer. Treas. Reg. 1.401(a)(9)-2(b)(2)(vi) reaches an employee 'born on or after January 1, 1960' and gives applicable age 75, so the current-edition candidate is 1960 plus 75, which is 2035. The April 2023 edition candidate, age 70 and a half: May 1960 plus 70 years is May 2030, plus 6 months is November 2030, so calendar 2030. Both 2030 and 2035 begin on or after 1 January 2025, so under 1.401(a)(9)-1(d) the current edition governs both and the case is settled. Computed. Row: preSecure era from a 2019-11-20 death; required beginning date 1 April 2036, which the death precedes, so rbd position 'before' and row A2.

  Technical details

  Case

  spouse-deferral-1960-computed

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1960-05-20","ownerDeathDate":"2019-11-20","beneficiaryBirthDate":"1966-01-05","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"A2"}

• a surviving spouse, born 12 September 1955, of an owner born 1 March 1952 who died 15 June 2021

  Expected value derived from the authority

  The straddle cohort with a death AFTER 2019. The ground is the owner's birth date, and the year of death is no part of it.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: When your deferral must begin turns on an unsettled reading

  How this was worked out: Owner born 1952-03-01 who died 2021-06-15, so the era is secure where every other case reaching this card has a pre-2020 death. That difference must not move the answer, and until 2026-08-26 it did: classify.ts applied the decline only inside its preSecure branch, so this owner computed while the identical owner with a 2018 death was declined. Candidate one, the April 1 2023 edition of Treas. Reg. 1.401(a)(9)-3, Q-3 A-3(b)(2), read from the eCFR versioner API for title 26 at issue date 2023-04-01: where the sole designated beneficiary is the surviving spouse, distributions must commence by the later of the end of the year following the death and 'The end of the calendar year in which the employee would have attained age 70 1/2'. March 1952 plus 70 years is March 2022, plus 6 months is September 2022, so calendar 2022. Candidate two, the current edition at issue date 2026-08-24: Treas. Reg. 1.401(a)(9)-3(d) defers to 'the end of the calendar year in which the employee would have attained the applicable age', and 1.401(a)(9)-2(b)(2)(iv) gives an employee 'born on or after January 1, 1951, but before January 1, 1959' an applicable age of 73, so 1952 plus 73 is 2025. Treas. Reg. 1.401(a)(9)-1(d) applies the current sections 'for purposes of determining required minimum distributions for calendar years beginning on or after January 1, 2025' and the April 1 2023 edition 'for earlier calendar years'. 2022 falls under the earlier edition and 2025 under the current one, so the two candidates straddle 1 January 2025 and neither edition governs both. Declined. What the era gate produced instead, and why it was worse than an ordinary wrong row: the applicable age of 73 gives a required beginning date of 1 April 2026, which the 2021 death precedes, so the case classified B2 and its schedule deferred commencement to 2025, the exact year the straddle turns on.

  Technical details

  Case

  spouse-deferral-1952-straddle-post-2020-death-declined

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1952-03-01","ownerDeathDate":"2021-06-15","beneficiaryBirthDate":"1955-09-12","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"spouseDeferralUnsettled"}

• a surviving spouse, born 10 February 1961, of an owner born 5 May 1959 who died 15 June 2021

  Expected value derived from the authority

  The reserved 1959 cohort with a death AFTER 2019. Same ground, same commencement year, and only the era row differs.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Deferred to the year the owner would have reached applicable age, then recalculated annually

  How this was worked out: The same reserved cohort with a death AFTER 2019, which is what proves the era is no part of the ground. Owner born 1959-05-05, died 2021-06-15, spouse remains a beneficiary of a traditional IRA. DERIVED FROM THE AUTHORITY, NOT THE ENGINE. The applicable-age chain is the one set out in spouse-deferral-1959-reserved: Treas. Reg. 1.401(a)(9)-2(b)(2)(v) is '[Reserved]' with (iv) stopping before 1959 and (vi) starting at 1960; T.D. 10001 at 89 FR 58891 footnote 7 records that IRC 401(a)(9)(C)(v) describes a 1959 birth at both 73 and 75; REG-103529-23 at 89 FR 58650 proposes 73 and was still proposed on 2026-08-26; John's decision of that date is to compute on 73 and disclose. Applicable age 73, attainment 2032, required beginning date 1 April 2033 under Treas. Reg. 1.401(a)(9)-2(b)(1). The 15 June 2021 death precedes it, so the owner died before the required beginning date. That death is after 31 December 2019, so 401(a)(9)(H) applies and the era is SECURE. Spouse beneficiary, SECURE era, before the required beginning date is row B2: the same deferral to the end of 2032, recalculated annually. THE PAIRING IS THE POINT. This case and its pre-2020 twin differ only in the year of death, and they must produce the same commencement year on the same ground. That is what the 2026-08-26 hoist out of the pre-SECURE branch established, and ending the 1959 decline preserves it. A change that splits the two again fails here. It must also carry the applicableAge1959 notice.

  Technical details

  Case

  spouse-deferral-1959-reserved-post-2020-death

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1959-05-05","ownerDeathDate":"2021-06-15","beneficiaryBirthDate":"1961-02-10","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B2"}

• a surviving spouse, born 20 August 1962, of an owner born 15 April 1960 who died 15 June 2021

  Expected value derived from the authority

  The post-2020 twin of spouse-deferral-1960-computed. One calendar year later than the reserved cohort, and it must still compute once the decline is era-blind.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Deferred to the year the owner would have reached applicable age, then recalculated annually

  How this was worked out: Owner born 1960-04-15 who died 2021-06-15, spouse born 1962-08-20 as sole beneficiary who has not treated the IRA as their own. This is the half that keeps 'decline in both eras' from being satisfied by an engine that simply declined every post-2020 spouse. Candidate one, April 1 2023 edition, Treas. Reg. 1.401(a)(9)-3 A-3(b)(2), age 70 and a half: April 1960 plus 70 years is April 2030, plus 6 months is October 2030, so calendar 2030. Candidate two, current edition, Treas. Reg. 1.401(a)(9)-3(d) with 1.401(a)(9)-2(b)(2)(vi), which reaches an employee 'born on or after January 1, 1960' at applicable age 75: 1960 plus 75 is 2035. Both 2030 and 2035 are calendar years beginning on or after 1 January 2025, so under Treas. Reg. 1.401(a)(9)-1(d) the current edition governs both and 1.401(a)(9)-3(d) names one year, 2035. Nothing is unsettled and the case computes. Row: the era is secure because the death falls after 31 December 2019. The required beginning date is 1 April of the year following applicable-age attainment, so 1 April 2036, and the 2021 death precedes it, giving rbd position 'before' and row B2 rather than B3. Commencement is deferred to 2035 under 1.401(a)(9)-3(d), so no year from 2026 through 2034 carries an annual minimum.

  Technical details

  Case

  spouse-deferral-1960-post-2020-death-computed

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1960-04-15","ownerDeathDate":"2021-06-15","beneficiaryBirthDate":"1962-08-20","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B2"}

• a surviving spouse, born 5 January 1966, of an owner born 10 March 1964 who died 20 November 2019

  Expected value derived from the authority

  The case that used to reach the unsettled card. A 1964 birth puts both candidate commencement years well past 2025, so one edition governs both and the schedule is computed.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Commencement deferred to the year the owner would have attained the applicable age, then recalculated annually

  How this was worked out: Owner born 1964-03-10 with a 2019-11-20 death, the exact facts that carried card-spouse-deferral-unsettled until 2026-08-26. Its derivation recorded the ground as 'a pre-2020 death does not imply a pre-1949 birth', which is true and irrelevant: Treas. Reg. 1.401(a)(9)-1(d) selects the edition by distribution calendar year from 2025 and names no death-year carve-out, so the year of death never chose between the two readings. Candidate one, April 2023 edition, age 70 and a half: March 1964 plus 70 years is March 2034, plus 6 months is September 2034, so calendar 2034. Candidate two, current edition: 1.401(a)(9)-2(b)(2)(vi), birth 'on or after January 1, 1960', applicable age 75, so 1964 plus 75 is 2039. Both 2034 and 2039 begin well after 1 January 2025, so the current edition governs both and 1.401(a)(9)-3(d) gives one year, 2039. The five-year gap between 2034 and 2039 is real but it is a gap between an edition that governs and one that does not, which is not an ambiguity. Computed. Row: preSecure era; required beginning date 1 April 2040, which the death precedes, so rbd position 'before' and row A2. This is also what makes roth-spouse-pre-2020-deferral-settled still worth having: both account types now compute on these facts, and what the account type moves is the deferral YEAR, 2039 traditional against 2034 Roth, which the roth-spouse-deferral-year goldens pin directly.

  Technical details

  Case

  spouse-deferral-1964-birth-now-computed

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1964-03-10","ownerDeathDate":"2019-11-20","beneficiaryBirthDate":"1966-01-05","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"A2"}

• a surviving spouse, born 5 January 1966, of an owner born 10 March 1964 who died 20 November 2019

  Expected value derived from the authority

  The Roth twin of spouse-deferral-1964-birth-now-computed. Same dates, same spouse, Roth instead of traditional, and it commences five years earlier because a different paragraph governs it.

  Account

  Roth IRA

  The rule that governs

  Commencement deferred to the year the owner would have attained the applicable age, then recalculated annually

  How this was worked out: Every input matches spouse-deferral-1964-birth-now-computed except the account type, so the account type is the only thing that can move the answer. Era: death 2019-11-20 is before 1 January 2020, so preSecure. Relationship: surviving spouse, sole beneficiary, who has NOT treated the Roth IRA as their own. RBD position: Treas. Reg. 1.408A-6 A-14(b) opens 'The minimum distribution rules apply to the Roth IRA as though the Roth IRA owner died before his or her required beginning date', so the position is 'before' whatever the owner's dates would otherwise give, and the era A spouse pair resolves to A2 rather than A3. Deferral year: the same paragraph A-14(b) closes 'If the sole beneficiary is the decedent's spouse, such spouse may delay distributions until the decedent would have attained age 70 1/2 or may treat the Roth IRA as his or her own.' The owner was born 1964-03-10, so age 70 falls on 2034-03-10 and age 70 and a half on 2034-09-10, which is calendar year 2034. That is one year, from one sentence, with no competing reading. What the account type moves, CORRECTED 2026-08-26: it is the deferral YEAR, not whether the case computes at all. The traditional twin was carded until the predicate was narrowed, and it no longer is, because Treas. Reg. 1.401(a)(9)-1(d) selects the edition by distribution calendar year from 2025 and both of a 1964 owner's candidate years, 2034 and 2039, fall on the same side of that date. So the traditional case computes too, off 1.401(a)(9)-3(d) and an applicable age of 75 under 1.401(a)(9)-2(b)(2)(vi), giving 2039. T.D. 10001 did not amend 1.408A-6, and A-14(b) as read on the eCFR title 26 issue of 2026-08-24 still says age 70 and a half outright, so the Roth case reaches 2034 instead, five years earlier, from a different authority. Both are row A2 and the roth-spouse-deferral-year goldens pin the Roth year directly. Decided by John 2026-08-26.

  Technical details

  Case

  roth-spouse-pre-2020-deferral-settled

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1964-03-10","ownerDeathDate":"2019-11-20","beneficiaryBirthDate":"1966-01-05","accountType":"roth","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"A2"}

• a surviving spouse, born 5 January 1966, of an owner born 10 March 1964 who died 20 November 2019

  Expected value derived from the authority

  The last year of the Roth spouse's deferral. Nothing is owed yet, and the year is one before the year the authority names.

  Account

  Roth IRA

  Checked for

  2033

  How this was worked out: Same facts as roth-spouse-pre-2020-deferral-settled: Roth IRA, owner born 1964-03-10 who died 2019-11-20, surviving spouse born 1966-01-05 as sole beneficiary who has NOT treated the Roth IRA as their own. Row A2. Treas. Reg. 1.408A-6 A-14(b), read from the eCFR versioner API for title 26 at issue date 2026-08-24, states: 'If the sole beneficiary is the decedent's spouse, such spouse may delay distributions until the decedent would have attained age 70 1/2 or may treat the Roth IRA as his or her own.' Arithmetic: the owner was born 1964-03-10, so age 70 falls on 2034-03-10 and age 70 and a half on 2034-09-10, whose calendar year is 2034. Distributions may therefore be delayed until 2034, so every year from 2020 through 2033 carries NO annual minimum, and 2033 is the last of them. The expectation carries a year and nothing else, which is not the same as a zero. This is the negative half of a pair: paired with roth-spouse-deferral-year-2034-commences it pins the boundary to one year, so a rule that deferred to the wrong year cannot satisfy both. The competing year is 2039, which is what Treas. Reg. 1.401(a)(9)-3(d) as amended by T.D. 10001 would give through the applicable age of 75 under IRC 401(a)(9)(C)(v) for a 1964 birth. T.D. 10001 did not amend 1.408A-6, so 2034 governs a Roth spouse and the two readings are five years apart. Decided by John 2026-08-26.

  Technical details

  Case

  roth-spouse-deferral-year-2033-no-minimum

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1964-03-10","ownerDeathDate":"2019-11-20","beneficiaryBirthDate":"1966-01-05","accountType":"roth","edbStatus":"neither"}

  Expected

  {"kind":"scheduleYear","year":2033}

• a surviving spouse, born 5 January 1966, of an owner born 10 March 1964 who died 20 November 2019

  Expected value derived from the authority

  The first year the Roth spouse owes anything, and the divisor for it. The positive half of the boundary pair.

  Account

  Roth IRA

  Divisor for 2034

  20.4

  How this was worked out: Same facts as roth-spouse-deferral-year-2033-no-minimum. Commencement year: Treas. Reg. 1.408A-6 A-14(b) permits delay 'until the decedent would have attained age 70 1/2'; the owner was born 1964-03-10, so 70 and a half is 2034-09-10 and the calendar year is 2034. 2034 is therefore the first distribution calendar year that carries an annual minimum. Divisor for 2034, under Treas. Reg. 1.401(a)(9)-5(d)(3)(iv): a sole surviving spouse's remaining life expectancy is REDETERMINED at the spouse's attained age in the distribution year itself, with no year-after-death anchor and no reduction by one. The spouse was born 1966-01-05 and so attains 2034 minus 1966 equals 68 in 2034. The Single Life Table at Treas. Reg. 1.401(a)(9)-9(b), Table 1, read from the eCFR versioner API for title 26 at issue date 2026-08-24, gives 20.4 for age 68. Greater-of does not apply: A-14(b) treats the Roth owner as having died before the required beginning date, so the row is A2 and Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) is never reached. Under the competing 2039 reading this year would carry nothing at all, so the pair is what separates the two authorities by more than a label.

  Technical details

  Case

  roth-spouse-deferral-year-2034-commences

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1964-03-10","ownerDeathDate":"2019-11-20","beneficiaryBirthDate":"1966-01-05","accountType":"roth","edbStatus":"neither"}

  Expected

  {"kind":"scheduleYear","year":2034,"divisor":20.4}

• a child of the owner, born 20 June 2010, of an owner born 10 April 1975 who died 15 August 2022

  Expected value derived from the authority

  The pre-flip annual denominator for the B8 minor child, at the current year.

  Account

  Traditional, SEP or SIMPLE IRA

  Divisor for 2026

  68.9

  How this was worked out: Facts of row-b8-minor-child-before-rbd: owner born 1975-04-10 died 2022-08-15, child born 2010-06-20. Treas. Reg. 1.401(a)(9)-5(d)(3)(iii) anchors a non-spouse beneficiary's remaining life expectancy at the beneficiary's age in the calendar year FOLLOWING the year of death. The year after death is 2023, and the child attains 13 in 2023, on 2023-06-20. Age 13 is the lookup, NOT age 12, which is the age in the year of death, and not age 16, which is the age in the current year; that off-by-one is the single most common error in this area. The current Single Life Table at Treas. Reg. 1.401(a)(9)-9(b) gives 71.9 for age 13. The anchor year is 2023, after 2021, so the 2022 reset at 1.401(a)(9)-9(f)(2) does not apply. Reduce by one for each calendar year elapsed after 2023: 2026 minus 2023 is 3, so 71.9 minus 3 equals 68.9.

  Technical details

  Case

  minor-child-of-owner-divisor-2026

  Inputs

  {"relationship":"childOfOwner","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1975-04-10","ownerDeathDate":"2022-08-15","beneficiaryBirthDate":"2010-06-20","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"scheduleYear","year":2026,"divisor":68.9}

• a child of the owner, born 20 June 2010, of an owner born 10 April 1975 who died 15 August 2022

  Expected value derived from the authority

  The age-21 flip year and the terminal deadline, both derived as dates.

  Account

  Traditional, SEP or SIMPLE IRA

  Account empty by

  31 December 2041

  How this was worked out: Facts of row-b8-minor-child-before-rbd. Treas. Reg. 1.401(a)(9)-4(e)(3) fixes the age of majority at the 21st birthday, so a child born 2010-06-20 reaches majority on 2031-06-20 and 2031 is the flip year. Treas. Reg. 1.401(a)(9)-5(e)(4) then sets the outer limit at the calendar year that includes the TENTH ANNIVERSARY OF THE DATE the beneficiary reaches the age of majority, which is 2041-06-20, so the calendar year is 2041 and the terminal deadline is 31 December 2041. The measurement runs from the majority DATE and not from the flip year plus ten, and not from the death; both shortcuts give 2041 here only because the anniversary falls mid-year, and a majority date of 31 December would separate them. Paragraph (e)(2), the tenth anniversary of the DEATH, does not apply because it is limited to a designated beneficiary who is not an eligible designated beneficiary. This case deliberately pins only the flip year and the deadline, and NOT an annual figure for 2031: whether an annual minimum continues in the post-majority years is the one place the spec's prose and Treas. Reg. 1.401(a)(9)-3(c)(4) appear to disagree, and the report says so rather than the fixture guessing.

  Technical details

  Case

  minor-child-of-owner-flip

  Inputs

  {"relationship":"childOfOwner","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1975-04-10","ownerDeathDate":"2022-08-15","beneficiaryBirthDate":"2010-06-20","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"scheduleYear","year":2031,"terminalDeadline":"2041-12-31"}

• a child of the owner, born 15 May 2012, of an owner born 5 March 1950 who died 10 September 2024

  Expected value derived from the authority

  The B9 minor child's current-year denominator, where greater-of actually has two candidates.

  Account

  Traditional, SEP or SIMPLE IRA

  Divisor for 2026

  70.9

  Account empty by

  31 December 2043

  How this was worked out: Facts of row-b9-minor-child-on-or-after-rbd: owner born 1950-03-05 died 2024-09-10, child born 2012-05-15. Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) makes the denominator the greater of the beneficiary's and the owner's remaining life expectancies. Beneficiary side, under (d)(3)(iii): the anchor year is 2025, the calendar year after the death, in which the child attains 13 on 2025-05-15, so the lookup age is 13 and not the 12 the child was in the year of death; the Single Life Table gives 71.9, reduced by one for the single year elapsed after 2025, which is 70.9 for 2026. Owner side, under (d)(3)(ii): the owner's life expectancy is anchored at the owner's age on their birthday in the YEAR OF DEATH, which is 2024 minus 1950 equals 74, giving 15.6, reduced by one for each of the two years elapsed after 2024, which is 13.6 for 2026. Note the two sides use different anchor years by design, 2025 for the beneficiary and 2024 for the owner. 70.9 is greater than 13.6, so the denominator is 70.9. Terminal deadline: the child's 21st birthday is 2033-05-15, and Treas. Reg. 1.401(a)(9)-5(e)(4) takes the calendar year containing its tenth anniversary, 2043-05-15, so 31 December 2043.

  Technical details

  Case

  minor-child-on-or-after-rbd-greater-of-2026

  Inputs

  {"relationship":"childOfOwner","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1950-03-05","ownerDeathDate":"2024-09-10","beneficiaryBirthDate":"2012-05-15","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"scheduleYear","year":2026,"divisor":70.9,"terminalDeadline":"2043-12-31"}

• a child of the owner, born 10 May 2003, of an owner born 10 February 1948 who died 1 July 2022

  Expected value derived from the authority

  The terminal deadline the regulation itself prints for Example 3, so this one is not our arithmetic at all.

  Account

  Traditional, SEP or SIMPLE IRA

  Account empty by

  31 December 2034

  How this was worked out: Treas. Reg. 1.401(a)(9)-4(e)(9)(iii), Example 3, states the answer in terms: because B was not disabled as of the date of A's death, B ceases to be an eligible designated beneficiary on reaching the age of majority in 2024, and 'Plan X is required to distribute A's remaining interest in the plan by the end of 2034 pursuant to the rules of 1.401(a)(9)-5(e)(4)'. Our encoding of the example gives the child a birth date of 2003-05-10, so majority falls on 2024-05-10 and the tenth anniversary on 2034-05-10, whose calendar year is 2034. The regulation's printed year and our derived year agree, which is what makes this a check on the arithmetic rather than only on the reading.

  Technical details

  Case

  example3-terminal-deadline-2034

  Inputs

  {"relationship":"childOfOwner","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1948-02-10","ownerDeathDate":"2022-07-01","beneficiaryBirthDate":"2003-05-10","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"scheduleYear","year":2034,"terminalDeadline":"2034-12-31"}

• another individual, born 1 June 1985, of an owner born 10 April 1950 who died 15 September 2025

  Expected value derived from the authority

  An owner who died in an earlier year with a possibly unpaid death-year RMD. The outcome is a schedule, with the notice alongside it.

  Account

  Traditional, SEP or SIMPLE IRA

  Divisor for 2026

  44.8

  Required for 2026

  $8,928.57

  Account empty by

  31 December 2035

  Required for 2035

  $495,870.98, the entire remaining balance

  How this was worked out: Owner born 1950-04-10, applicable age 72 under IRC 401(a)(9)(C)(v), attained 2022, required beginning date 1 April 2023; death 2025-09-15 is on or after it, and Treas. Reg. 1.401(a)(9)-5(c)(1) says in terms that a required minimum distribution IS due for the calendar year of the owner's death and must be distributed during that year to the beneficiary to the extent not already distributed to the owner. That 2025 item is a Notice and never a card: it accompanies the schedule and does not replace it. The schedule itself, for 2026: the beneficiary was born 1985-06-01 and is more than 10 years younger than the 1960-04-10 cutoff with neither status attested, so not an EDB, and the row is B5. Beneficiary side under 1.401(a)(9)-5(d)(3)(iii): the anchor year is 2026, the year after the death, in which the beneficiary attains 41, giving 44.8 from the Single Life Table, with no reduction because 2026 IS the anchor year. Owner side under (d)(3)(ii): the owner attained 75 in the 2025 year of death, giving 14.8, reduced by one for 2026, which is 13.8. Greater-of picks 44.8. Terminal deadline under 1.401(a)(9)-5(e)(2): the calendar year containing the tenth anniversary of the death, 2035-09-15, so 31 December 2035. DOLLARS, on the money the schedule tests pass: an opening balance of 400,000.00 at 31 December 2025 and a growth rate of 5 percent, walked in the six-step order projection.ts documents, namely (1) opening balance is the prior 31 December balance, (2) the minimum is computed from it, (3) the minimum is subtracted, (4) the remainder is grown at the growth rate, (5) any year-end contribution is credited and an inherited schedule has none, (6) the result is floored at zero and becomes the next year's opening balance. 2026: opening 400,000.0000, divisor 44.8, so the annual minimum is 400,000 divided by 44.8, which is 8,928.5714, or 8,928.57 to the cent. Step 3 leaves 391,071.4286 and step 4 grows it to 410,625.0000 exactly, so 2027 opens at 410,625.00. Divisor for 2027: the beneficiary's side under 1.401(a)(9)-5(d)(3)(iii) is 44.8 reduced by the one year elapsed after the 2026 anchor, which is 43.8, and the owner's side under (d)(3)(ii) is 14.8 reduced by the two years elapsed after the 2025 year of death, which is 12.8, so the greater-of takes 43.8. The 2027 annual minimum is 410,625 divided by 43.8, which is 9,375.0000 exactly. Only the 2027 opening balance is produced by the balance recurrence at all; 2026's is the input. TERMINAL YEAR 2035: the requirement is the entire remaining balance and there is no divisor, so the amount required IS that year's opening balance. It is derived without walking ten rows by hand, because the factors telescope. Each year from 2026 to 2034 multiplies the balance by (d minus 1) over d and then by 1.05, with d running 44.8, 43.8, and so on down to 36.8, and the owner's side never wins in any of them since it runs 13.8 down to 5.8. The numerators 43.8 through 35.8 cancel against the denominators 43.8 through 36.8, leaving 35.8 over 44.8. So the 2035 opening balance is 400,000 times 35.8 divided by 44.8 times 1.05 to the ninth power, which is 319,642.8571 times 1.5513282160, which is 495,870.9833, or 495,870.98 to the cent. That figure is the year's whole requirement.

  Technical details

  Case

  death-year-notice-with-schedule

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"tenYear","ownerBirthDate":"1950-04-10","ownerDeathDate":"2025-09-15","beneficiaryBirthDate":"1985-06-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"scheduleYear","year":2026,"divisor":44.8,"terminalDeadline":"2035-12-31","openingBalance":400000,"annualMinimum":8928.5714,"nextYear":{"year":2027,"openingBalance":410625,"divisor":43.8,"annualMinimum":9375},"terminalYear":{"year":2035,"openingBalance":495870.9833}}

• a surviving spouse, born 30 November 1962, of an owner born 5 August 1960 who died 1 March 2024

  Expected value derived from the authority

  A B2 spouse in 2026 owes nothing yet. A tool that starts the schedule at the current year invents a requirement.

  Account

  Traditional, SEP or SIMPLE IRA

  Checked for

  2026

  How this was worked out: Facts of spouse-not-yet-treated-as-own: owner born 1960-08-05 died 2024-03-01 before the required beginning date of 1 April 2036, surviving spouse sole beneficiary born 1962-11-30. Treas. Reg. 1.401(a)(9)-3(d) permits commencement to be delayed until the end of the calendar year in which the employee would have attained the applicable age. The owner's applicable age is 75 under IRC 401(a)(9)(C)(v) for a 1960 birth, so that year is 1960 plus 75, which is 2035. The current RMD year is 2026, nine years before commencement is required, so there is NO annual minimum for 2026 and no terminal deadline either, the ten-year rule being unavailable to an eligible designated beneficiary taking life expectancy payments. The expectation therefore carries a year and nothing else, deliberately: absent is not the same as zero, and a row reading 'no annual minimum' is the honest output.

  Technical details

  Case

  spouse-recalculated-no-minimum-before-deferred-commencement

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1960-08-05","ownerDeathDate":"2024-03-01","beneficiaryBirthDate":"1962-11-30","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"scheduleYear","year":2026}

• a surviving spouse, born 14 February 1950, of an owner born 12 September 1948 who died 4 July 2022

  Expected value derived from the authority

  A B3 spouse's current-year denominator: recalculated life expectancy, compared against the owner's fixed term.

  Account

  Traditional, SEP or SIMPLE IRA

  Divisor for 2026

  14.1

  Required for 2026

  $28,368.79

  How this was worked out: Facts of row-b3-spouse-beneficiary-on-or-after-rbd: owner born 1948-09-12 died 2022-07-04 on or after the required beginning date of 1 April 2020, spouse born 1950-02-14 as sole beneficiary. Spouse side, under Treas. Reg. 1.401(a)(9)-5(d)(3)(iv): a sole surviving spouse's remaining life expectancy is REDETERMINED each distribution calendar year at the spouse's age in that year, not fixed and reduced by one. The spouse attains 2026 minus 1950 equals 76 in 2026, so the Single Life Table value is read at age 76, giving 14.1. Age 76 is the lookup because it is the age in the CURRENT year; there is no year-after-death anchor on the spouse branch, which is the difference from every non-spouse case in this fixture. Owner side, under (d)(3)(ii): the owner attained 2022 minus 1948 equals 74 in the year of death, giving 15.6, reduced by one for each of the four years elapsed after 2022, which is 11.6 for 2026. Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) takes the greater, so 14.1. On these facts the spouse's side wins in every year, because a spouse close in age to the owner is redetermined upward relative to a term that falls by a full year annually; for the case where the OWNER's side wins instead, see greater-of-owner-side-wins. DOLLARS, two consecutive years, on the money the schedule tests pass: an opening balance of 400,000.00 at 31 December 2025 and a growth rate of 5 percent. projection.ts documents six steps and this follows them in that order: (1) the opening balance is the prior 31 December balance; (2) the year's minimum is computed FROM that opening balance; (3) the minimum is subtracted from it; (4) the remainder is grown at the growth rate; (5) any year-end contribution is credited, and an inherited schedule has none; (6) the result is floored at zero and becomes the next year's opening balance. 2026: opening 400,000.0000, divisor 14.1, so the annual minimum is 400,000 divided by 14.1, which is 28,368.7943, or 28,368.79 to the cent. Step 3 leaves 371,631.2057 and step 4 grows it by 5 percent to 390,212.7660, so 2027 opens at 390,212.77. Divisor for 2027: the spouse attains 2027 minus 1950 equals 77, and Treas. Reg. 1.401(a)(9)-5(d)(3)(iv) redetermines rather than reduces, so the Single Life Table at 1.401(a)(9)-9(b) is read at age 77, giving 13.3; the owner's side under (d)(3)(ii) is 15.6 reduced by the five years elapsed after the 2022 year of death, which is 10.6; Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) takes the greater, 13.3. The 2027 annual minimum is 390,212.7660 divided by 13.3, which is 29,339.3057, or 29,339.31 to the cent. The SECOND year is the one that carries the evidence: the 2026 opening balance is an input and the 2026 minimum is that input over a divisor pinned above, so 2027's opening balance is the only figure here the balance recurrence actually produces. Row B3 has no terminal deadline, so there is no terminal amount to pin; that half is pinned by death-year-notice-with-schedule.

  Technical details

  Case

  spouse-greater-of-2026

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1948-09-12","ownerDeathDate":"2022-07-04","beneficiaryBirthDate":"1950-02-14","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"scheduleYear","year":2026,"divisor":14.1,"openingBalance":400000,"annualMinimum":28368.7943,"nextYear":{"year":2027,"openingBalance":390212.766,"divisor":13.3,"annualMinimum":29339.3057}}

• another individual, born 1 March 1940, of an owner born 10 January 1948 who died 1 May 2022

  Expected value derived from the authority

  The one case where the greater-of rule changes the number: a beneficiary OLDER than the owner, so the owner's own remaining life expectancy is the larger figure.

  Account

  Traditional, SEP or SIMPLE IRA

  Divisor for 2026

  11.6

  How this was worked out: Owner born 1948-01-10, in the pre-1 July 1949 cohort, so the applicable age is 70 and a half, attained July 2018, required beginning date 1 April 2019, and the death on 2022-05-01 is on or after it. The beneficiary is the owner's older sibling, born 1940-03-01, so the ten-years-younger test at Treas. Reg. 1.401(a)(9)-4(e)(6) is satisfied trivially and the beneficiary is an EDB, giving row B7. Beneficiary side under Treas. Reg. 1.401(a)(9)-5(d)(3)(iii): the anchor year is 2023, the year after death, in which the beneficiary attains 83; the Single Life Table gives 9.3, reduced by one for each of the three years elapsed after 2023, which is 6.3 for 2026. Owner side under (d)(3)(ii): the owner attained 74 in the 2022 year of death, giving 15.6, reduced by one for each of the four years elapsed after 2022, which is 11.6 for 2026. Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) takes the greater, so 11.6, which is the OWNER's figure. A tool that used only the beneficiary's life expectancy would take 6.3 here and demand nearly twice the distribution the law requires. Nothing in this fixture would catch that omission without this case, because every other greater-of case has the beneficiary winning.

  Technical details

  Case

  greater-of-owner-side-wins

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1948-01-10","ownerDeathDate":"2022-05-01","beneficiaryBirthDate":"1940-03-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"scheduleYear","year":2026,"divisor":11.6}

• another individual, born 1 March 1940, of an owner born 10 January 1948 who died 1 May 2022

  Expected value derived from the authority

  The same facts as a classification, so the B7 row is reached by an older beneficiary as well as by a ten-years-younger one.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Lifetime, on the greater-of denominator

  How this was worked out: Same facts as greater-of-owner-side-wins. Era: death 2022-05-01, so secure. Relationship: a sibling, an unrelated individual for these purposes. EDB: Treas. Reg. 1.401(a)(9)-4(e)(6) determines the not-more-than-10-years-younger category from the two dates of birth, and a beneficiary born 1940-03-01 is nearly eight years OLDER than an owner born 1948-01-10, so the category is met with room to spare. RBD: 1 April 2019 as derived there, and the death is on or after it. Row B7, lifetime on the greater-of denominator with no terminal deadline.

  Technical details

  Case

  greater-of-owner-side-wins-classification

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1948-01-10","ownerDeathDate":"2022-05-01","beneficiaryBirthDate":"1940-03-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B7"}

• another individual, born 1 October 1963, of an owner born 1 October 1953 who died 1 June 2026

  Expected value derived from the authority

  An EDB whose owner died this year owes no annual minimum this year. Commencement is by the end of NEXT year.

  Account

  Traditional, SEP or SIMPLE IRA

  Checked for

  2026

  How this was worked out: Facts of ten-years-younger-boundary-eligible: owner born 1953-10-01 died 2026-06-01 before the required beginning date of 1 April 2027, beneficiary born 1963-10-01 and so an EDB under Treas. Reg. 1.401(a)(9)-4(e)(6). Treas. Reg. 1.401(a)(9)-3(c)(4) requires annual distributions to COMMENCE by the end of the calendar year FOLLOWING the year of death, which is 2027. So no annual minimum is required for 2026, the year of death itself. Nor is there a death-year owner RMD, because the owner died before the required beginning date and Treas. Reg. 1.401(a)(9)-5(c)(1)'s year-of-death distribution applies only where distributions had begun. The 2026 row is therefore empty of requirements, and the expectation carries a year and nothing else.

  Technical details

  Case

  edb-no-minimum-in-year-of-death

  Inputs

  {"relationship":"otherIndividual","inheritedFrom":"owner","otherBeneficiaries":"none","ownerBirthDate":"1953-10-01","ownerDeathDate":"2026-06-01","beneficiaryBirthDate":"1963-10-01","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"scheduleYear","year":2026}

• a surviving spouse, born 10 February 1961, of an owner born 1 January 1952 who died 1 June 2026

  Expected value derived from the authority

  A straddle-cohort owner who died past BOTH candidate required beginning dates. No commencement year arises under either edition, so nothing is unsettled and the case computes.

  Account

  Traditional, SEP or SIMPLE IRA

  The rule that governs

  Greater-of denominator

  How this was worked out: Owner born 1952-01-01, in the straddle cohort, who died 2026-06-01. DERIVED FROM THE AUTHORITY, NOT THE ENGINE. Treas. Reg. 1.401(a)(9)-2(b)(2)(iv), eCFR title 26 at issue date 2026-08-25, gives an employee born on or after 1 January 1951 and before 1 January 1959 an applicable age of 73, so attainment is 2025 and the required beginning date under 1.401(a)(9)-2(b)(1) is 1 April 2026. Under the April 2023 edition the same deferral ran off age 70 and a half, which this owner attained in 2022, giving a required beginning date of 1 April 2023. The two candidate commencement years, 2022 and 2025, fall on opposite sides of the 1 January 2025 applicability date in Treas. Reg. 1.401(a)(9)-1(d), so this owner IS in the straddle cohort and was declined until 2026-08-26. The death on 1 June 2026 is on or after BOTH candidate required beginning dates. Under either edition distributions had already begun, so Treas. Reg. 1.401(a)(9)-3(d)'s deferral does not apply and no commencement year arises for the two readings to disagree about. Both editions also place the death on the same side of the required beginning date, so both select the same row. Death after 31 December 2019 makes the era SECURE under 401(a)(9)(H); spouse beneficiary, on or after the required beginning date, is row B3, the greater-of denominator under 1.401(a)(9)-5(d)(1)(ii). This is the case stage 4a's final review carried: a straddle-cohort owner already past their required beginning date, refused an answer for an uncertainty their facts cannot contain.

  Technical details

  Case

  straddle-past-both-beginning-dates-computed

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1952-01-01","ownerDeathDate":"2026-06-01","beneficiaryBirthDate":"1961-02-10","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"classified","rowId":"B3"}

• a surviving spouse, born 10 February 1961, of an owner born 1 January 1952 who died 1 June 2024

  Expected value derived from the authority

  The same owner dying between the two candidate required beginning dates, where the editions disagree about the ROW and not merely about a commencement year.

  Account

  Traditional, SEP or SIMPLE IRA

  Outcome

  Declined: When your deferral must begin turns on an unsettled reading

  How this was worked out: The same owner dying BETWEEN the two candidate required beginning dates, which is the case that most needs to stay declined. DERIVED FROM THE AUTHORITY, NOT THE ENGINE. Owner born 1952-01-01: applicable age 73 under Treas. Reg. 1.401(a)(9)-2(b)(2)(iv), attainment 2025, required beginning date 1 April 2026; age 70 and a half in 2022 under the April 2023 edition, required beginning date 1 April 2023. The death on 1 June 2024 is on or after 1 April 2023 and before 1 April 2026. So the April 2023 edition places it ON OR AFTER the required beginning date and the current edition places it BEFORE, and the two do not merely name different commencement years, they select DIFFERENT ROWS: the greater-of denominator of Treas. Reg. 1.401(a)(9)-5(d)(1)(ii) under one reading and the deferred, annually redetermined commencement of 1.401(a)(9)-3(d) under the other. That is a larger disagreement than the one the card was written for, so it is declined with the same card. It is paired with straddle-past-both-beginning-dates-computed deliberately: the two differ only in the year of death and must land on opposite outcomes, which is what stops the 2026-08-26 narrowing from being widened into a blanket rule that any straddle-cohort death after 2019 computes.

  Technical details

  Case

  straddle-between-the-two-beginning-dates-declined

  Inputs

  {"relationship":"spouse","spouseHasTreatedAsOwn":false,"inheritedFrom":"owner","otherBeneficiaries":"none","governingMethod":"lifeExpectancy","ownerBirthDate":"1952-01-01","ownerDeathDate":"2024-06-01","beneficiaryBirthDate":"1961-02-10","accountType":"traditional","edbStatus":"neither"}

  Expected

  {"kind":"declined","card":"spouseDeferralUnsettled"}

What it will not compute, and why

A calculator that confidently declines a case it cannot model is worth more than one that produces a precise wrong number for it. These are the edges, in full.

• When your deferral must begin turns on an unsettled reading

  The calendar year your custodian treats as the year distributions had to begin, and whether they treat them as having begun already. Treasury Regulation 1.401(a)(9)-3(d) defers a sole surviving spouse to the end of the year the owner would have attained the applicable age, and Treasury Regulation 1.401(a)(9)-1(d) applies that text only to distribution calendar years beginning on or after 1 January 2025; for earlier years the April 2023 edition of the same regulations governs, and it ran that deferral off age 70 and a half instead. Where the owner was born between 1 January 1952 and 30 June 1954, those two readings name years that fall on opposite sides of 1 January 2025, so no single edition settles the commencement year, and Treasury Regulation 1.401(a)(9)-3(e)(3) can treat distributions as having begun whether or not anything was paid. We would be starting your schedule from a commencement year we cannot stand behind, so we say so instead.

• This account is left to a trust

  Whether the trust is a see-through trust, and if so which of its beneficiaries the plan treats as the account's designated beneficiaries. That answer decides the schedule and it depends on the trust's own terms, which this calculator cannot read.

• This account is left to an estate, a charity or another organisation

  The distribution period that applies where there is no designated beneficiary. It is not a life expectancy, because there is no life to measure, and it differs depending on whether the owner had reached their required beginning date.

• You inherited this from someone who had already inherited it

  The schedule the first beneficiary was on and when it began. A successor generally continues that existing schedule rather than starting a new one, so the figures turn on facts about someone else's account.

• This account has more than one beneficiary and was not split by the deadline

  Whether separate accounts were established by the applicable deadline. Where they were not, the beneficiaries are measured together rather than individually, which can change every schedule involved.

• We cannot tell which distribution method governs this account

  Your custodian for the method currently in force: annual life expectancy amounts, the ten-year rule, the old five-year rule, or an annuity. What has been withdrawn so far does not reveal it, and guessing would produce a confident wrong schedule.

• You are asking about the surviving spouse election under SECURE 2.0 section 327

  This one is not settled law yet. The operational rules sit in proposed regulations, and the IRS has said the final regulations amending 1.401(a)(9)-4, -5 and -6 will not apply earlier than six months after they are issued, with taxpayers applying a reasonable good-faith interpretation in the meantime. We would rather decline than compute an answer on rules that are not yet applicable.

  • Announcement 2026-7, 2026-11 I.R.B. 697 (verified 2026-08-26)