IRS written determination 202624001

Private letter rulings and published taxpayer determination letters. Native document type is retained separately; a determination letter is not labeled a private letter ruling. These taxpayer-specific releases cannot be used or cited as precedent under 26 USC 6110(k)(3); applicability and current legal force are not independently certified. Keep repeated UILC subjects attached to one actual numbered document.

Internal Revenue Service
Department of the Treasury
Washington, DC 20224
Number: 202624001
Release Date: 6/12/2026
Index Number: 408.00-00, 401.06-00,
408.06-00

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Third Party Communication: None
Date of Communication: Not Applicable
Person To Contact:
--------------------, ID No. -----------------
Telephone Number:
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Refer Reply To:
CC:EEE:EB:QP1
PLR-114415-25
Date:
February 20, 2026
Legend

Decedent = ----------------------------------------------------------------------------
Taxpayer A = ------------------------------------------------
Taxpayer B = ---------------------------------------------------
Taxpayer C = ----------------------------------------------------
State S = ----------------
IRA X = -----------------------------------------------------------
Date 1 = ------------------
Date 2 = --------------------------
Date 3 = -----------------------
Date 4 = ----------------------

Dear -------------:

This is in response to your request, dated April 1, 2025, for a letter ruling under sections
408 and 401(a)(9) of the Internal Revenue Code (Code).

The following facts and representations have been submitted under penalties of perjury
in support of the rulings requested.

Decedent died on Date 2, survived by three children, Taxpayer A, Taxpayer B, and
Taxpayer C (Beneficiaries).

Decedent owned IRA X, a traditional individual retirement arrangement (IRA). Decedent
had attained the applicable age to begin receiving required minimum distributions from
IRA X before death. The custodian for IRA X maintains there is no record of a

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beneficiary designation for IRA X. Therefore, Decedent’s estate is treated as the sole
beneficiary of IRA X.

On Date 1, Decedent executed a Last Will and Testament naming the Beneficiaries as
beneficiaries of IRA X and the other assets in Decedent’s residuary estate, to be divided
equally. On Dates 3 and 4, a court in State S admitted Decedent’s will to probate and
appointed Taxpayer A as the sole executor to administer Decedent’s estate.

As the sole executor, Taxpayer A proposes to divide IRA X into 3 equal parts and
transfer each part, by means of trustee-to-trustee transfers, to separate inherited IRAs
for the benefit of Taxpayer A, Taxpayer B, and Taxpayer C (Beneficiaries’ Inherited
IRAs). Each of the Beneficiaries’ Inherited IRAs will be titled “Decedent (Deceased) IRA
f/b/o [Beneficiary’s Name] as beneficiary of Decedent's estate.”

Taxpayer A, Taxpayer B, and Taxpayer C will receive required minimum distributions
from the Beneficiaries’ Inherited IRAs using Decedent’s remaining life expectancy, until
the assets of each inherited IRA are fully withdrawn or dissipated.

This letter assumes that IRA X and the Beneficiaries’ Inherited IRAs satisfy the
requirements of § 408 at all relevant times.

Requested Rulings

Based on the above facts and representations, you, through your authorized
representative, request the following rulings:

1. As the beneficiaries of Decedent’s interest in IRA X, each Beneficiary’s
respective interest in IRA X may be segregated and held in separate IRAs for
purposes of determining each Beneficiary’s required minimum distributions under
§ 401(a)(9).

2. The Beneficiaries’ Inherited IRAs, being titled in Decedent’s name for the benefit
of each Beneficiary, funded by means of trustee-to-trustee transfers from IRA X,
constitute inherited IRAs under § 408(d)(3).

3. The Beneficiaries may each receive distributions required under § 401(a)(9) from
each Beneficiary’s specific inherited IRA (set up in Decedent’s name for the
benefit of that Beneficiary, as a beneficiary of Decedent’s estate) over
Decedent’s remaining life expectancy.

4. The transfer of each Beneficiary’s respective interest in the estate’s interest in
IRA X to the Beneficiaries’ Inherited IRAs will not constitute a taxable distribution
within the meaning of § 408(d)(1) to each Beneficiary and does not constitute a
rollover as the term is used in § 408(d)(3).

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3
Law

Under § 408(a)(6) and the regulations thereunder, rules similar to the rules of
§ 401(a)(9) and the incidental death benefit requirements of § 401(a) apply to the
distribution of the entire interest of an individual for whose benefit an IRA is maintained.

Treas. Reg. § 1.408-8(a)(1) provides that an IRA is subject to the required minimum
distribution rules under § 401(a)(9). In order to satisfy § 401(a)(9), the rules of
§§ 1.401(a)(9)-1 through 1.401(a)(9)-9 must be applied, except as otherwise provided.
Section 1.408-8(a)(3) provides that for purposes of applying the required minimum
distribution rules in § 1.401(a)(9)-1 through 1.401(a)(9)-9, the IRA trustee, custodian or
issuer is treated as the plan administrator, and the IRA owner is substituted for the
employee.

Section 401(a)(9)(A) provides, in general, that a trust will not be considered qualified
unless the plan provides that the entire interest of each employee (a) will be distributed
to such employee not later than the required beginning date, or (ii) will be distributed,
beginning not later than the required beginning date, over the life of such employee or
over the lives of such employee and a designated beneficiary or over a period not
extending beyond the life expectancy of such employee or the life expectancy of such
employee and a designated beneficiary.

Section 401(a)(9)(B)(i) provides, in general, that if an employee dies after distribution of
his interest has begun in accordance with § 401(a)(9)(A)(ii) (after the required beginning
date), the remaining portion of his interest must be distributed at least as rapidly as
under the method of distribution being used as of the date of death.

Section 401(a)(9)(C)(i) provides, in relevant part and for the relevant time period, that
for purposes of this paragraph, the term “required beginning date” means April 1 of the
calendar year following the calendar year in which the employee attains the applicable
age (as defined in § 401(a)(9)(C)(v).

Section 401(a)(9)(E)(i) provides that for purposes of § 401(a)(9), the term designated
beneficiary means any individual designated as a beneficiary by the employee.

Section 1.401(a)(9)-4(b) states that a person that is not an individual, such as the
employee's estate, is not a designated beneficiary for purposes of § 401(a)(9). If a
person other than an individual is a beneficiary designated under the plan, the decedent
will be treated as having no designated beneficiary, even if individuals are also
designated as beneficiaries.

Section 1.401(a)(9)-4(c) provides, in relevant part, that in order to be a designated
beneficiary, an individual must be a beneficiary as of the date of the employee’s death.
Generally, a person is a beneficiary taken into account for purposes of § 401(a)(9) if, as
of the date of the employee's death, that person is a beneficiary designated under the

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plan who remains a beneficiary as of September 30 of the calendar year following the
calendar year of the date of death (that is, has not received the entire benefit to which
the beneficiary is entitled before that September 30).

Section 1.401(a)(9)-5(d)(1)(iii) provides, in summary, that if an employee dies on or after
his required beginning date without having a designated beneficiary, then post-death
distributions must be made over the applicable remaining life expectancy of the
employee determined in accordance with § 1.401(a)(9)-5(d)(3)(ii).

Section 1.401(a)(9)-5(d)(3) provides that, for purposes of calculating an employee’s
required minimum distributions, all life expectancies are determined using the Single
Life Table in § 1.401(a)(9)-9(b). Under § 1.401(a)(9)-5(d)(3)(ii), the employee's
remaining life expectancy is determined initially using the employee's age as of the
employee's birthday in the calendar year of the employee's death. In subsequent
calendar years, the remaining life expectancy is determined by reducing that initial life
expectancy by one for each calendar year that has elapsed after that first calendar year.

Section 1.401(a)(9)-8(a)(1)(i) provides that § 401(a)(9) is applied separately with
respect to the separate interests of each of the employee's beneficiaries under the plan
provided that those interests are held in separate accounts that satisfy the separate
accounting requirements. Under § 1.401(a)(9)-8(a)(2)(ii), a separate accounting
satisfies the requirements if all post-death investment gains and losses, contributions,
forfeitures, and expenses for the period prior to the establishment of the separate
accounts are allocated on a pro rata basis in a reasonable and consistent manner
among the separate accounts. The separate accounting does not fail to satisfy the
separate accounting requirements because, in lieu of a pro rata allocation of investment
gains and losses (A) separate accounts are established that have separate
investments; and (B) the investment gains and losses attributable to assets held in each
of those separate accounts are allocated only to that separate account.

The relevant Single Life Table determining life expectancy is provided in § 1.401(a)(9)-
9(b).

Section 408(d)(1) provides that, except as otherwise provided in § 408(d), any amount
paid or distributed out of an IRA shall be included in gross income by the payee or
distributee, as the case may be, in the manner provided under § 72.

Section 408(d)(3)(A) provides that § 408(d)(1) does not apply to any amount paid or
distributed out of an IRA to the individual for whose benefit the IRA is maintained if: (i)
the entire amount received (including money and any other property) is paid into an IRA
for the benefit of such individual not later than the 60th day after the day on which the
individual receives the payment or distribution, or (ii) the entire amount received
(including money and any other property) is paid into an eligible retirement plan (other
than an IRA) for the benefit of such individual not later than the 60th day after the date
on which the payment or distribution is received, except that the maximum amount

PLR-114415-25

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which may be paid into such plan may not exceed the portion of the amount received
which is includible in gross income (determined without regard to § 408(d)(3)).

Section 408(d)(3)(C) provides, generally, that amounts from an “inherited” IRA cannot
be rolled over into another IRA. In general, an “inherited” IRA is an IRA maintained by
an individual who acquired the IRA by reason of the death of another individual if the
acquiring individual is not the surviving spouse of the other individual.

Section 408(d)(3)(E) provides that the rollover provisions of § 408(d) do not apply to any
amount required to be distributed under § 408(a)(6) (regarding required minimum
distributions under § 401(a)(9)).

Revenue Ruling 78-406, 1978-2 C.B. 157, provides that the direct transfer of funds from
one IRA trustee to another IRA trustee, even if at the behest of the IRA holder, does not
constitute a payment or distribution to a participant, payee or distribute, as those terms
are used in § 408(d). Furthermore, such a transfer does not constitute a rollover
distribution. Revenue Ruling 78-406 specifically applies in the case of a transfer by the
original IRA owner from one IRA titled in the IRA owner's name to another IRA titled in
the same manner.

Rulings

The rules discussed above will apply to your ruling requests as follows:

1. As the beneficiaries of Decedent’s interest in IRA X, each Beneficiary’s
respective interest in IRA X may be segregated and held in separate IRAs for
purposes of determining each Beneficiary’s required minimum distributions under
§ 401(a)(9).

2. The Beneficiaries’ Inherited IRAs, being titled in Decedent’s name for the benefit
of each Beneficiary, funded by means of trustee-to-trustee transfers from IRA X,
constitute inherited IRAs under § 408(d)(3).

3. The Beneficiaries may each receive distributions required under § 401(a)(9) from
each Beneficiary’s specific inherited IRA (set up in Decedent’s name for the
benefit of that Beneficiary, as a beneficiary of Decedent’s estate) over
Decedent’s remaining life expectancy.

4. The transfer of each Beneficiary’s respective interest in the estate’s interest in
IRA X to the Beneficiaries’ Inherited IRAs will not constitute a taxable distribution
within the meaning of § 408(d)(1) to each Beneficiary and does not constitute a
rollover as the term is used in § 408(d)(3).

The rulings contained in this letter are based upon information and representations
submitted by Taxpayer A and accompanied by a penalty of perjury statement executed

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by Taxpayer A, as specified in Rev. Proc. 2026-1, 2026-1 I.R.B. 1, § 7.01(16)(b). While
this office has not verified any of the material submitted in support of the request for
rulings, it is subject to verification on examination. The Associate office will revoke or
modify a letter ruling and apply the revocation retroactively if there has been a
misstatement or omission of controlling facts, the facts at the time of the transaction are
materially different from the controlling facts on which the ruling was based, or, in the
case of a transaction involving a continuing action or series of actions, the controlling
facts materially change during the course of the transaction. See Rev. Proc. 2026-1,
§ 11.05.

Except as expressly provided above, no opinion is expressed or implied concerning the
federal income tax consequences of any other aspects of any transaction or item of
income described in this letter ruling.

This letter is directed only to the taxpayer requesting it. Section 6110(k)(3) of the Code
provides that it may not be used or cited as precedent.

In accordance with the Power of Attorney on file with this office, a copy of this letter is
being sent to your authorized representative.

Sincerely,

/s/ Neil S. Sandhu

Neil S. Sandhu
Senior Technician Reviewer
Qualified Plans Branch 1
Office of the Associate Chief Counsel
(Employee Benefits, Exempt Organizations, and
Employment Taxes)

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