If there are multiple beneficiaries, the life expectancy of the oldest beneficiary will be used as the distribution period for purposes of determining required minimum distributions. A person who has a right to an employee's benefit as only a potential successor to the interest of one of the employee's beneficiaries upon that first beneficiary's death is not considered a beneficiary. The 2002 final regulations clarify that this rule does not apply to a person who has any right to an employee's benefit beyond a mere potential successor to the interest of one of the employee's beneficiaries upon the death of that beneficiary.
Thus, if a beneficiary has an income interest in a deceased's IRA and a second beneficiary has the remainder interest, the second beneficiary's life expectancy must be considered in determining who are the deceased - designated beneficiaries.
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