FEDZONE Ed Zurndorfer

A recent FEDZONE column discussed the RMD rules for a spousal TSP beneficiary participant. This FEDZONE column discusses the beneficiary participant withdrawal rules when a non-spouse is designated as the beneficiary of a TSP account.

When a designated beneficiary of a TSP participant’s account is a trust or an individual (who is not the participant’s spouse), the portion of a deceased TSP participant’s account that is inherited by a trust or an individual is temporarily placed in a separate account. Non-spousal beneficiaries in this category may request immediate payment once the temporary account is established. However, after 90 days the TSP will automatically make a lump-sum payment to the designated non-spousal beneficiary. If there is more than one designated non-spousal beneficiary, then after 90 days each non-spousal beneficiary will be sent in a lump-sum payment their inherited portion of the deceased TSP participant’s account.  A separate lump-sum payment is made for the inherited traditional TSP account and the inherited Roth TSP account.

The lump-sum payment of an inherited traditional TSP account will most likely be disadvantageous to the non-spousal beneficiary with respect to federal and state income taxes. This is because the lump-sum payment will be made within one calendar year and could push the beneficiary into a higher federal and state marginal tax bracket. With respect to the inherited Roth TSP account, while there is no tax liability associated with the lump-sum payment of the  Roth TSP account, once the beneficiary receives the Roth TSP account, the tax-free compounded growth of the Roth TSP account ceases.

Fortunately, as discussed next, non-spousal TSP beneficiaries have a tax-beneficial option with respect to what they can do with their inherited traditional TSP and inherited Roth TSP accounts.

Direct Distribution of An Inherited TSP Account to An Inherited (“Death”) IRA

The IRS categorizes the lump-sum payment of a deceased TSP participant’s TSP account as an eligible distribution. This distribution is for the benefit of a non-spousal beneficiary. A non-spousal TSP beneficiary has the option of directly distributing their inherited TSP account to an inherited (“death”) IRA. The inherited traditional TSP account can be directly distributed to a traditional inherited (“death”) IRA and the inherited Roth TSP account can be directly distributed to a Roth inherited (“death”) IRA. An Inherited (“death”) IRA is not a contributory IRA in which the IRA owner can make regular contributions each year. An inherited (“death”) IRA can only be funded with inherited qualified retirement plan funds such as funds coming from a deceased TSP participant’s account.

If there are multiple non-spousal TSP beneficiaries, then each non-spousal beneficiary has the option of directly distributing his or her inherited TSP account to an inherited (“death”) IRA.

Required Distributions from Inherited (“Death”) IRAs

Inherited (“death”) IRA owners are required to withdraw their accounts within a certain period of time. There are two options for withdrawing the accounts:

  • Five-year rule. Under this rule, the entire account must be distributed by the end of the fifth year after the year the TSP participant dies. No distribution is required for any year before the end of the fifth year.
  • Ten-year rule. A ten-year rule applies to non-qualified designated beneficiaries (those other than eligible designated beneficiaries, see below who is considered an eligible designated beneficiary). The inherited (“death”) IRA must be distributed entirely by the end of the tenth year following the year of the TSP participant’s death. For an inherited (“death”) traditional IRA in which the IRA owner is a non-qualified designated beneficiary, required minimum distributions (RMDs) must be taken during years 1 through 9 following the year of the TSP participant’s death. The RMD is calculated using the longer of the non-qualified designated beneficiary’s life expectancy (as of the beneficiary’s age in the calendar year following the TSP participant’s death) or the TSP participant’s life expectancy in the year of the TSP participant’s death. If the distributions are based on the beneficiary’s life expectancy, the RMD for each year is calculated using the inherited (“death”) IRA balance at the end of the previous year divided by the initial life expectancy factor (using the IRS Single Life Expectancy table). This is based on the inherited (“death”) IRA owner’s age in the year the inherited (“death”) IRA was established. Subsequent RMDs for the remainder of the 10-year period are calculated based on the inherited IRA balance as of the last day of the preceding year, divided by the initial single life expectancy reduced by the number of years that have elapsed since the year of the TSP participant’s death.

Note the following:

  1. An eligible designated beneficiary has the option of withdrawing from his or her inherited (“death”) IRA based on their life expectancy and does not have to withdraw the inherited IRA by the end of the 10th year following the death of the TSP participant. Eligible designated beneficiaries include: (1) The surviving spouse of the deceased TSP participant; (2) A disabled or chronically ill individual;  (3) A minor child of the TSP participant; and (4) Any other individual no more than 10 years younger than the deceased TSP participant.

 


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2. There is no RMD requirements for an inherited(“death”) Roth IRA. An inherited (“death”) Roth IRA owner can therefore wait until December 31 of the tenth year following the year of death of the Roth TSP participant to withdraw the entire inherited (“death”) Roth IRA. The owner is therefore encouraged to wait until the end of the tenth to withdraw the Roth account in order to allow the inherited Roth account to grow tax-free to the maximum extent possible.

3. When there are multiple non-spousal beneficiaries of a TSP participant’s account, and each beneficiary directly distributed their inherited TSP account to their own inherited (“death”) IRAs, there is a 10-year distribution requirement for each non-spousal beneficiary. Each non-spousal beneficiary must take an RMD during years through 9. The RMD calculation will be based on the single life expectancy of the oldest beneficiary.

The following example illustrates the required distributions from a deceased TSP participant’s traditional TSP account and a Roth TSP account.

Francine, a federal retiree, passed away in July 2024 at the age of 71. Francine was a widow. She named her two daughters, Jean (age 42) and Colleen (age 39) as the beneficiaries of her traditional TSP account and her Roth TSP account. Jean and Colleen each inherited 50 percent of Francine’s traditional TSP account and Roth TSP account. At the time of Francine’s death, Francine’s traditional TSP account balance was $840,500 and her Roth TSP account balance was $220,750. Both Jean and Colleen directly distributed their inherited TSP accounts to their own inherited (“death”) IRAs. At the time of the direct distribution, the traditional TSP account was worth $870,100 while the Roth TSP account was worth $260,552. As of December 31,2024, the value of both Jean’s and Colleen’s traditional inherited (“death”) IRA was $435,050 (half of $870,100) and the value of both Jean’s and Colleen’s Roth inherited (”death”) IRA was $130,276 (half of $260,552).

Under the 10-year rule, Jean and Colleen must withdraw their traditional inherited (“death”) IRA accounts no later than December 31, 2034, the end of the 10th year following  the year of Francine’s death. Jean and Colleen can wait until the end of 2034 to withdraw their Roth inherited (“death” IRA accounts.

Jean and Colleen must each take an RMD from their traditional inherited (“death”) IRAs each year during the 10-year period. The RMD is calculated by obtaining the value of the traditional inherited (“death”) IRA as of the last day of the previous year and dividing that amount by a life expectancy factor. The life expectancy factor is the Single Life Expectancy based on the age of the older beneficiary (Jean) following the year of Francine’s death. Jean is age 43 during 2025, the year following Francine’s death. From the IRS Single Life Expectancy Tabe, the life expectancy of a 43-year-old is 42.9. Therefore, for the year 2025, the first year, both Jean and Colleen must withdraw from their traditional inherited (“death”) IRA the minimum  amount (RMD) of:

$435,050 (value of traditional IRA as of 12/31/2024)/42.9 (single life expectancy for a 43-year-old)

 = $10,141.03

For years 2 through 9, the RMDs re calculated using the previous end-of-year traditional inherited/death IRA balance and the 42.9 life expectancy decreased by 1.0 for each year after the first year. The following table summarizes the calculation of the 10-year payment RMDS following Francine’s death in 2024:

         (a)

 

Year

(b)

Payment Number

(c)

Traditional Inherited (“death”) IRA Balance as of the End of the Previous Year

(d)

Single Life Expectancy Factor

(e)

RMD

[(c)/(d)]

2025 1 12/31/2024: $435,050 42.9 $10,141.03
2026 2 12/31/2025 41.9 -
2027 3 12/31/2026 40.9 -
2028 4 12/31/2027 39.9 -
2029 5 12/31/2028 38.9 -
2030 6 12/31/2029 37.9 -
2031 7 12/31/2030 36.9 -
2032 8 12/31/2031 35.9 -
2033 9 12/31/2032 34.9 -
2034 10 12/31/2033 - *

* Entire account must be withdrawn by 12/31/2034

* This chart is for illustration purposes only

Note that Jean and Colleen can withdraw more than the RMD during years 1 through 9. But withdrawing more than the RMD will likely result in additional federal and state income taxes, and possible loss of tax credits and tax deductions due to larger adjusted gross income. Jean and Colleen are therefore advised to speak to their tax advisors in order to determine how taking more than the RMD will affect their annual federal income tax and state income tax liabilities and possible loss of tax credits and tax deductions due to higher adjusted gross incomes.

The Thrift Savings Plan (TSP) is a retirement savings and investment plan for Federal employees and members of the uniformed services, including the Ready Reserve. The TSP is a defined contribution plan, meaning that the retirement income you receive from your TSP account will depend on how much you (and your agency or service, if you're eligible to receive agency or service contributions) put into your account during your working years and the earnings accumulated over that time. The Federal Retirement Thrift Investment Board (FRTIB) administers the TSP. Contributions to a traditional IRA may be tax-deductible depending on the taxpayer’s income, tax-filing status, and other factors. Withdrawal of pre-tax contributions and/or earnings will be subject to ordinary income tax and, if taken prior to age 59 1/2, may be subject to a 10% federal tax penalty. RMD's are generally subject to federal income tax and may be subject to state taxes. Consult your tax advisor to assess your situation. The mentioned case study is for illustrative purposes only. Individual cases will vary. Any information is not a complete summary or statement of all available data necessary for making an investment decision and does not constitute a recommendation. Prior to making any investment decision, you should consult with your financial advisor about your individual situation.

Edward A. Zurndorfer is a CERTIFIED FINANCIAL PLANNER™ professional, Chartered Life Underwriter, Chartered Financial Consultant, Chartered Federal Employee Benefits Consultant, Certified Employees Benefits Specialist and IRS Enrolled Agent in Silver Spring, MD. Tax planning, Federal employee benefits, retirement and insurance consulting services offered through EZ Accounting and Financial Services, and EZ Federal Benefits Seminars, located at 833 Bromley Street - Suite A, Silver Spring, MD 20902-3019 and telephone number 301-681-1652. Raymond James is not affiliated with and does not endorse the opinions or services of Edward A. Zurndorfer or EZ Accounting and Financial Services. The information has been obtained from sources considered to be reliable, but we do not guarantee that the foregoing material is accurate or complete. While we are familiar with the tax provisions of the issues presented herein, as Financial Advisors of RJFS, we are not qualified to render advice on tax or legal matters. You should discuss tax or legal matters with the appropriate professional.


Ed Zurndorfer, EA, ATA, CFP®, CLU®, ChFC®, CEBS®, ChFEBC℠: Federal Employee Benefits Expert

A former career Federal employee, Ed has published a staggering 1,200+ separate articles on Federal Benefits and Retirement!
Just “Google” his name, and you are likely to find a plethora of sites that contain his writings. Drawn to its mission to reach, teach
and serve Feds, Serving Those Who Serve is the only financial planning practice with which Ed has chosen to affiliate in over
20 years teaching. In addition to conducting Federal Benefits seminars for Serving Those Who Serve, you can find Ed’s
writings here on our blog in the FedZone, and on Fed-Soup, MyFederalRetirement, FederalNews Radio and NITP.

He is a member of the Maryland Society of Accountants, the National Association of Enrolled Agents, the International Society of Certified Employee Benefits Specialists, the Financial Planning Association, the National Association of Health Underwriters,
and the Society of Financial Service Professionals. Since 1999, Ed has taught many thousands of Federal employees about
their benefits, in person and at Federal agencies all over the country. Ed is a true national treasure.

Edward A. Zurndorfer is a CERTIFIED FINANCIAL PLANNER™ professional, Chartered Life Underwriter, Chartered Financial Consultant, Chartered Federal Employee Benefits Consultant, Certified Employees Benefits Specialist and IRS Enrolled Agent in Silver Spring, MD. Tax planning, Federal employee benefits, retirement and insurance consulting services offered through EZ Accounting and Financial Services, and EZ Federal Benefits Seminars, located at 833 Bromley Street - Suite A, Silver Spring, MD 20902-3019 and telephone number 301-681-1652. Raymond James is not affiliated with and does not endorse the opinions or services of Edward A. Zurndorfer or EZ Accounting and Financial Services. The information has been obtained from sources considered to be reliable, but we do not guarantee that the foregoing material is accurate or complete. While we are familiar with the tax provisions of the issues presented herein, as Financial Advisors of RJFS, we are not qualified to render advice on tax or legal matters. You should discuss tax or legal matters with the appropriate professional.