Eligible Designated Beneficiary Taxonomy in 2026: The Four Non-Spouse EDB Categories, the SECURE Act 10-Year Rule Carve-Outs, and the Single Life Table Math

The SECURE Act of 2019 rewrote the beneficiary rules for retirement accounts, and the rewrite is still working its way through the trust documents, beneficiary designations, and estate plans of every American who has meaningful money in a 401(k) or IRA. The core change: most beneficiaries lost the lifetime "stretch" and were forced onto a 10-year distribution window under IRC §401(a)(9)(H).^[1] The tax cost of the change has been six figures on a routine $500K–$2M inherited-account handoff, because 10 years of accelerated ordinary-income distributions almost always collide with a beneficiary's peak-earning decade.

But the statute carved out five categories that keep the older, more forgiving treatment. These are the Eligible Designated Beneficiaries (EDBs) at IRC §401(a)(9)(E)(ii).^[2] An EDB can — subject to some traps this article walks through — stretch inherited-account distributions over their own single-life expectancy, keeping the account compounding tax-deferred for decades instead of a decade. On a $1M inherited IRA, the difference between the 10-year rule and lifetime stretch for a 45-year-old EDB is more than $600,000 of preserved after-tax balance, depending on bracket assumptions and account growth.

Yesterday we published the complete surviving-spouse decision framework. The spouse is the most privileged EDB category — the only one with both stretch and a full ownership rollover. This article covers the other four categories, each of which has a materially different qualification rule, a materially different stretch mechanic, and a materially different loss-of-status trap. Together, they cover almost every non-spouse inheritance scenario where the 10-year rule can be legally avoided.

When you are ready to project the numbers on any specific inheritance, the CalcLeap retirement calculator, the Traditional IRA calculator, and the 401(k) withdrawal calculator handle the arithmetic under both the stretch and 10-year regimes. This article walks through the statute, the four categories in order of frequency, the July 2024 final regulations (TD 10001) that finally locked in the operating rules, SECURE 2.0 §337 Applicable Multi-Beneficiary Trusts, three worked case studies with hand-checked numbers, and every mistake we have seen turn what should be a decades-long stretch into an accelerated 10-year burnout.

What the SECURE Act broke and what the EDB carve-outs preserved

Before December 31, 2019, any individual beneficiary of an inherited IRA or 401(k) could elect to stretch distributions over their own single-life expectancy under Treas. Reg. §1.401(a)(9)-5. A 30-year-old daughter inheriting a $1M IRA from her 65-year-old father took an initial RMD of roughly $18,000 (single-life divisor 55.3 at age 30) and continued for 55 years — the account compounded tax-deferred for a lifetime and the family paid ordinary income tax only on the trickle that came out each year.^[3]

The SECURE Act ended that regime for most beneficiaries. IRC §401(a)(9)(H), effective for deaths after December 31, 2019, requires the entire inherited account balance to be distributed by December 31 of the tenth calendar year after the account owner's death.^[1] Under the July 2024 final regulations at Treas. Reg. §1.401(a)(9)-5 (TD 10001), if the deceased owner died on or after their required beginning date (RBD, age 73 in 2026 under SECURE 2.0 §107), the beneficiary must also take annual RMDs during years 1–9 of the 10-year window at a level roughly matching what the deceased would have taken, with the full balance out by year-10 December 31.^[4]

The five EDB categories at IRC §401(a)(9)(E)(ii) are:^[2]

1. The surviving spouse of the decedent — covered in our separate surviving-spouse decision framework.
2. A minor child of the decedent, until reaching the age of majority.
3. A disabled individual within the meaning of IRC §72(m)(7).
4. A chronically ill individual within the meaning of IRC §7702B(c)(2), with a modification.
5. Any other designated beneficiary who is not more than 10 years younger than the decedent.

EDB status is determined once — at the date of the account owner's death. The status generally does not change during the beneficiary's lifetime, with the important exception of the minor-child category, where reaching age 21 collapses the EDB status into the 10-year rule.^[5]

EDB Category 2: A minor child of the decedent

The minor-child EDB is one of the most misunderstood categories, primarily because two things about it are counterintuitive. First, it is only available to a minor child of the decedent — not a grandchild, not a niece or nephew, not a stepchild who was never legally adopted, and not a minor family friend. Second, the EDB status is not permanent — it evaporates when the child reaches age 21, at which point the 10-year rule engages and the child must fully distribute the remaining account balance by December 31 of the year the child turns 31.^[5]

The definition of "child" for this purpose follows IRC §152(f)(1) — a son, daughter, stepson, stepdaughter, or eligible foster child of the taxpayer, whether by blood or legal adoption. A stepchild who lived in the household but was never adopted qualifies as a stepchild if the marriage was intact at date of death. A grandchild does NOT qualify — even if the grandchild is the primary beneficiary because the grandchild's parent (the decedent's child) predeceased the decedent.^[2]

The age-of-majority question was one of the most contested parts of the July 2024 final regulations. The original SECURE Act tied age of majority to state law, which created a 50-state patchwork where the same beneficiary could be an EDB in one state and not another (some states use 18, some 21, and a few allow attainment upon marriage or completion of secondary school). Treasury resolved this in the final regulations by setting age 21 uniformly for all states.^[4] A minor child EDB retains stretch status until December 31 of the year they turn 21, and then the 10-year clock starts.

Distribution mechanics for a minor-child EDB

During the EDB period (birth-of-inheritance through age 21), the minor child takes annual RMDs based on the Single Life Table under Treas. Reg. §1.401(a)(9)-9, using the child's attained age at the start of each distribution year — with annual recalculation.^[6] A child inheriting at age 10 uses divisor 74.8; at age 15, divisor 70.1; at age 20, divisor 65.4. The RMDs are modest — roughly 1.3% to 1.5% of prior-year-end balance — which lets the account continue to compound largely tax-deferred through the child's minor years.

The custodial dimension matters here. A minor child cannot legally own an IRA in their own name — the account must be held by a custodian under the Uniform Transfers to Minors Act (UTMA) or Uniform Gifts to Minors Act (UGMA) in the child's state, or under a court-supervised guardianship of the estate. The choice of custodial vehicle has significant income-tax implications: an UTMA-held inherited IRA has all distributions taxed to the child (kiddie tax under IRC §1(g) applies for unearned income above $2,700 in 2026), while a guardianship-held account may have different reporting depending on the state.^[7]

What about a minor who is NOT a child of the decedent?

A grandchild, niece, nephew, or minor family friend is NOT an EDB even during their minority. They are a regular designated beneficiary and are subject to the 10-year rule from the account owner's date of death. This is one of the most common misconceptions in estate planning: many parents assume their minor grandchildren "must" get some kind of stretch. They do not. If the grandchild is a minor, the 10-year rule still applies — the distributions can be paid to the custodial UTMA account, but the full balance must be out by December 31 of the tenth year following the account owner's death, regardless of the grandchild's age at that point.^[2]

EDB Category 3: A disabled individual

The disabled-individual EDB category is the most powerful — it grants lifetime stretch to a qualifying beneficiary of any age, and (unlike the minor-child category) the status does not evaporate at any age milestone. It is also the category with the most technical qualification requirements, and the category most likely to be lost through poor documentation.

The statutory definition of "disabled" for EDB purposes is at IRC §401(a)(9)(E)(ii)(III), which references IRC §72(m)(7): an individual is disabled if they are unable to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment that can be expected to result in death or to be of long-continued and indefinite duration.^[8] This is the same definition used for the §72(t)(2)(A)(iii) exception to the 10% early-withdrawal penalty — a body of guidance and case law that goes back to the 1970s.

The July 2024 final regulations at §1.401(a)(9)-4(e)(4) added detailed operating rules for the disabled EDB category:^[4]

• Physician certification required from a licensed U.S. physician, filed with the plan administrator by October 31 of the year following the year of the account owner's death.
• Under-age-18 presumption: a beneficiary under 18 at the account owner's death is presumed disabled if they have a medically determinable impairment resulting in "marked and severe functional limitations" — a standard borrowed from the Social Security Act's childhood disability rules.
• Social Security disability determination is treated as sufficient evidence of disability but is not required. A beneficiary receiving Social Security Disability Insurance (SSDI) or Supplemental Security Income (SSI) on the basis of disability at the account owner's death is automatically deemed to qualify.
• Prior VA disability determination at 100% total-and-permanent rating is also treated as sufficient evidence.
• Improvement does not disqualify. A disabled beneficiary who later recovers or returns to work does not lose EDB status. The final regulations lock in status at date of death.

The Special Needs Trust workaround

A common estate-planning fact pattern involves a disabled beneficiary who receives means-tested government benefits (Medicaid, SSI, in-home supports and services). Direct receipt of an inherited IRA typically disqualifies the beneficiary from these benefits — the IRA is a countable resource, and even the annual RMD is countable income.

The workaround is a first-party or third-party Special Needs Trust (SNT) as beneficiary of the IRA. Under Treas. Reg. §1.401(a)(9)-4(f), a see-through trust with a disabled EDB as sole beneficiary (or, after SECURE 2.0 §337, as one of multiple beneficiaries in an Applicable Multi-Beneficiary Trust) can pass through the EDB stretch to the disabled beneficiary while shielding the assets from Medicaid resource counting.^[9]

EDB Category 4: A chronically ill individual

The chronically ill EDB is a parallel category to the disabled EDB, but with a materially different qualification standard drawn from the long-term-care insurance world.

The statutory definition at IRC §401(a)(9)(E)(ii)(IV) references IRC §7702B(c)(2), the long-term care insurance definition of "chronically ill individual," with a modification: for EDB purposes, the chronic illness must be indefinite and reasonably expected to be lengthy in nature.^[10] The base §7702B(c)(2) definition covers an individual who has been certified by a licensed health care practitioner as either:

1. Being unable to perform at least two Activities of Daily Living (ADLs) — eating, toileting, transferring, bathing, dressing, and continence — without substantial assistance from another individual, for a period of at least 90 days due to a loss of functional capacity.
2. Requiring substantial supervision to protect from threats to health and safety due to severe cognitive impairment (Alzheimer's disease, dementia, traumatic brain injury with lasting cognitive effect).

The July 2024 final regulations at §1.401(a)(9)-4(e)(5) tightened the certification timing: the licensed health care practitioner's certification must have been obtained within one year before the account owner's death, and the certification (or a substantially similar document showing the qualifying condition existed at date of death) must be filed with the plan administrator by October 31 of the year following the year of death.^[4]

Chronically ill vs. disabled — which category should the certification cite?

The two categories overlap significantly in practice. A beneficiary with advanced ALS, late-stage multiple sclerosis, or severe stroke sequelae will typically qualify under both the disability and the chronic-illness definitions. Where both fit, the disabled-EDB category is generally preferable because:

• The disability standard has decades of established case law and IRS guidance, while the chronically ill standard is newer and less tested.
• The disability documentation is often already in place — SSDI/SSI awards, VA ratings, and Medicare pre-65 enrollment records all support qualification without a new physician certification.
• The chronic-illness annual recertification and "obtained within one year before death" timing is more susceptible to being lost by a beneficiary or family that isn't sophisticated about the deadlines.

Where the beneficiary has a qualifying loss of ADL function but does NOT meet the "substantial gainful activity" disability standard (they can still work part-time, for instance), the chronically ill category is the fallback. A physician who is willing to make either certification should be asked to make the disability certification first.

EDB Category 5: Not more than 10 years younger than the decedent

This is the most common non-spouse EDB category in practice. Adult siblings, unmarried life partners, elderly parents inheriting from adult children, and non-relative beneficiaries in close-age-cohort relationships all typically qualify under this category.

The rule at IRC §401(a)(9)(E)(ii)(V) is mechanical: an individual is an EDB if their date of birth is no more than 10 years after the decedent's date of birth. The Treas. Reg. §1.401(a)(9)-4(e)(6) implementation compares dates precisely — a beneficiary born exactly 10 years and 1 day after the decedent does NOT qualify. A beneficiary born 10 years to the day after the decedent DOES qualify (the beneficiary is "not more than 10 years younger").^[4]

The comparison uses full dates of birth from the decedent's most recent birthday and the beneficiary's date of birth. It is not an age comparison at date of death — the statute is precise about date-of-birth-to-date-of-birth. A 65-year-old decedent who dies with a 74-year-old beneficiary is easy: beneficiary is older than decedent, so the "not more than 10 years younger" test is trivially satisfied. The interesting cases are close-cohort beneficiaries where the 10-year threshold is at the edge — a decedent born January 15, 1960 and a beneficiary born June 3, 1970 easily satisfies the rule (beneficiary is 10.4 years younger by date-of-birth comparison at a superficial read, but the regulations count the difference as approximately 10 years and 4.5 months — which fails).

Distribution mechanics for the §401(a)(9)(E)(ii)(V) EDB

Once qualified, the not-more-than-10-years-younger EDB takes annual RMDs based on the Single Life Table with the beneficiary's attained age each year. Unlike the surviving spouse and the minor-child EDB (both of whom get annual recalculation), the not-more-than-10-years-younger EDB uses the "subtract 1 each year" convention: year-1 divisor is the Single Life factor at the beneficiary's attained age in the year after the account owner's death, and each subsequent year's divisor is reduced by exactly 1.^[6]

On a $1M inherited IRA, a 65-year-old beneficiary (Single Life factor 22.9 at age 65) has a year-1 RMD of $43,668. Year 2 divisor is 21.9, RMD from year-2 balance. Year 3 divisor is 20.9, and so on. The divisor exhausts at approximately year 22 (age 87), at which point the full remaining balance is a required distribution. Practically, the stretch runs 18–22 years for a beneficiary in their 60s and 25–30 years for a beneficiary in their 50s — a materially better outcome than the 10-year rule.

SECURE 2.0 §337 Applicable Multi-Beneficiary Trusts

The original SECURE Act had a drafting gap that penalized certain trusts benefiting a disabled or chronically ill beneficiary alongside other (non-EDB) beneficiaries. If the trust was a see-through with multiple beneficiaries, the shortest-life beneficiary's rule applied — which usually meant the 10-year rule governed the entire trust distribution, defeating the point of naming a disabled or chronically ill beneficiary at all.

SECURE 2.0 §337, codified at IRC §401(a)(9)(H)(v), added the Applicable Multi-Beneficiary Trust (AMBT) fix effective for distributions in tax years beginning after December 29, 2022.^[11] An AMBT is a see-through trust with a disabled or chronically ill EDB as beneficiary that qualifies for EDB stretch under one of two structures:

1. Type I AMBT (subdivided trust): the trust is divided into separate accounts by September 30 of the year following the account owner's death. Each disabled or chronically ill beneficiary's share is held under a separate accumulation trust structure. The disabled/chronically ill beneficiary's share gets full lifetime stretch. The other beneficiaries' shares are subject to whichever rule normally applies (10-year rule for most non-EDB designated beneficiaries).
2. Type II AMBT (drafted priority): the trust is drafted so that no non-disabled, non-chronically-ill beneficiary receives any distribution from the trust until the disabled or chronically ill EDB dies. The entire inherited IRA can be held in a single trust with lifetime stretch based on the disabled/chronically ill EDB's life expectancy. Upon that beneficiary's death, the remaining balance can pass to other beneficiaries under the trust terms, subject to a 10-year rule from the EDB's date of death.

When EDB status ends and the 10-year clock starts

EDB status is not permanent. Four fact patterns collapse EDB stretch into the 10-year rule:^[4]

1. Minor child reaches age 21. Uniform under the July 2024 final regs — irrespective of state law. The 10-year clock starts December 31 of the year the child turns 21, requiring full distribution by December 31 of the year the child turns 31.
2. EDB dies before full distribution. The successor beneficiary is subject to the 10-year rule from the date of the EDB's death (not from the original account owner's death). Even if the successor is themselves an EDB, they are bound by the 10-year rule.
3. EDB elects the 10-year rule voluntarily. If the account owner died before their required beginning date, Treas. Reg. §1.401(a)(9)-3(c)(5) permits the EDB to elect the 10-year rule instead of stretch. The election is irrevocable and is documented via the beneficiary distribution election form filed with the custodian.
4. Documentation deadline missed. If the required documentation of EDB status is not provided to the plan administrator by October 31 of the year following the year of death, the beneficiary defaults to the non-EDB treatment (10-year rule). This is the most common way EDB status is lost quietly.

The Single Life Table math: EDB stretch vs. the 10-year rule

The dollar impact of EDB status on a specific account is the difference between two distribution schedules over the beneficiary's expected inheritance horizon. On a $1M inherited Traditional IRA growing at 6% net of distributions, the EDB stretch preserves substantially more cumulative after-tax value than the 10-year rule at every beneficiary age.^[6]

The "preserved balance" column is the delta between the account balance at year 10 under EDB stretch versus the account balance at year 10 (which is $0) under the 10-year rule, expressed in present-value 2026 dollars assuming a 22% marginal ordinary tax rate on distributions and 6% pre-tax growth. Individual results vary based on bracket assumptions, growth, and whether the beneficiary reinvests distributions in taxable accounts — but the sign is always the same: EDB stretch dominates the 10-year rule by six figures on a seven-figure account.

Three worked case studies

Case study 1: Aiden, 8, inherits $1.4M Traditional IRA from father Ravi who died at 46

Aiden is 8 years old. His father Ravi dies unexpectedly at 46 with a $1.4M Traditional IRA. Ravi's spouse (Aiden's mother) is named as primary beneficiary; Aiden is named contingent. The mother, wanting to preserve Aiden's inheritance and knowing her own financial situation is already comfortable, executes a §2518 qualified disclaimer within 9 months of Ravi's death — passing the account to Aiden as contingent beneficiary.

Aiden qualifies as a minor-child EDB. His mother, as court-appointed UTMA custodian, opens an inherited IRA in Aiden's name. Because Ravi died before his required beginning date (age 73), no year-of-death RMD is owed for Ravi's final year. Starting in the year after Ravi's death:

• Year 1 (Aiden age 9): Single Life divisor 75.8, RMD $18,470 on year-end balance $1.4M.
• Year 6 (Aiden age 14): Single Life divisor 70.9, RMD ~$22,500 on a balance grown to approximately $1.6M despite modest distributions.
• Year 12 (Aiden age 20): Single Life divisor 65.4, RMD ~$28,000 on a balance approaching $1.9M.
• Year 13 (Aiden turns 21): the EDB stretch ends. The full remaining balance (~$2.0M) must be distributed by December 31 of the year Aiden turns 31.

Aiden's tax planning during the accelerated 10-year window (age 21–31) becomes the critical variable. If Aiden pursues higher education and has modest earned income during those years, the family can time distributions into low-bracket years — potentially pulling out $150K-$200K per year in the 12% and 22% brackets, versus what would have been 24% or 32% rates if the distributions had been forced into a normal working career. With careful planning, Aiden clears the account with roughly $1.7M in cumulative after-tax value — versus perhaps $1.3M if the distributions were treated as ordinary income at Aiden's expected age-30 marginal bracket.

The delta from proper minor-child EDB documentation and 10-year-window tax planning: approximately $400,000 in preserved after-tax value versus a default 10-year rule with no planning.

Case study 2: Priya, 34, inherits $2M Traditional IRA from mother — Priya is disabled

Priya is 34, with muscular dystrophy that qualifies her under the §72(m)(7) disability standard. She receives SSDI and part-time contract work income. Her mother dies at 68 with a $2M Traditional IRA. Priya is named sole primary beneficiary. Because the mother had not yet reached her RBD, there is no year-of-death RMD.

Priya's advisor confirms disabled-EDB status by filing with the custodian:

• The Social Security Administration's Notice of Award for Priya's SSDI benefits.
• A one-page physician certification confirming the §72(m)(7) disability standard is met.
• Certified death certificate and beneficiary designation.

All three items are filed by October 31 of the year following the mother's death — meeting the §1.401(a)(9)-4(e) documentation deadline.

Priya's year-1 RMD at age 35: Single Life divisor 50.5, RMD ~$39,600 on the $2M balance. Assuming 6% growth net of distributions, the account continues to grow slowly through Priya's 40s and 50s, hitting approximately $2.4M by her age 60. Priya's cumulative after-tax distributions across her expected 45-year stretch horizon exceed $3.5M — versus roughly $2.1M under the 10-year rule with distributions concentrated into a decade of Priya's 30s.

The delta: more than $1.4M in preserved lifetime after-tax value. In addition, because Priya's SSDI and part-time work income are low, the annual RMDs land almost entirely in the 12% and 22% brackets — where the 10-year-rule alternative would have pushed her into 24% and even 32% for the decade the account had to burn out.

Case study 3: Marcus, 62, inherits $850K Traditional IRA from brother Neal (age 68)

Marcus is 62, retired, no children. His brother Neal dies at 68 (before RBD) with an $850K Traditional IRA. Marcus is named sole primary beneficiary. Marcus is 6 years younger than Neal (date of birth Sep 1962 vs. Neal's date of birth Aug 1956), well within the "not more than 10 years younger" threshold.

Marcus qualifies as an EDB under §401(a)(9)(E)(ii)(V). Documentation is straightforward — birth dates from the death certificate and Marcus's driver's license, filed with the custodian by October 31 of the year after Neal's death.

Marcus's year-1 RMD (year after Neal's death, Marcus age 63): Single Life divisor 24.5, RMD ~$34,700 on the $850K balance. Marcus's divisor decreases by exactly 1 each year (no annual recalculation for this EDB category): year 2 divisor 23.5, year 3 divisor 22.5, and so on.

Marcus decides to layer Roth conversions from his own Traditional IRA on top of the inherited-IRA RMDs during his 60s, using the inherited-IRA RMDs to cover living expenses so his personal Roth conversion capacity is preserved. Over Marcus's ~24-year stretch horizon, cumulative distributions from the inherited IRA total ~$1.1M — versus ~$970K under the 10-year rule, with the difference driven by continued tax-deferred compounding across the stretch period.

The delta: ~$130K in preserved after-tax value plus the meaningful qualitative benefit of Marcus's ability to keep his personal Roth conversion runway intact through his 60s. This is a smaller-dollar case than #1 and #2, but it illustrates why the not-more-than-10-years-younger category is worth checking on every non-spouse inheritance — it turns up more often than people expect, and the documentation cost is trivial.

Six expensive EDB mistakes

Mistake 1: Missing the October 31 documentation deadline

The most common way EDB status is lost. Documentation must be filed with the plan administrator or IRA custodian by October 31 of the year following the year of the account owner's death. Miss it, and the default is the 10-year rule. There is no cure. Certified death certificates take 4–6 weeks to obtain, physician certifications require appointments, and birth-date documentation may need to come from other states — start immediately after death.

Mistake 2: Assuming a minor grandchild is an EDB

A grandchild is NOT a minor-child EDB under §401(a)(9)(E)(ii)(II) — that category is limited to a child of the decedent. If a minor grandchild is named as beneficiary (or takes as contingent), the 10-year rule applies from the date of the account owner's death regardless of the grandchild's age. The distributions can go to a UTMA account for the minor grandchild, but the account must be fully distributed by December 31 of the tenth year after the account owner's death.

Mistake 3: Physician certification obtained too long before death

For chronically ill EDB status, the July 2024 final regulations require the physician certification to have been obtained within one year before the account owner's death. A certification from 3 years earlier does not satisfy the timing test even if the medical facts remain the same. If a beneficiary's chronic-illness qualification is likely to be relevant, request a fresh certification annually.

Mistake 4: Naming a charity as a permitted beneficiary of the see-through trust

A see-through trust that names a charity as a permitted beneficiary of income or principal — even in a contingent capacity — loses see-through status entirely under Treas. Reg. §1.401(a)(9)-4(f). Once see-through is lost, the trust is treated as a non-individual beneficiary and the entire inherited account must be distributed within 5 years (pre-RBD death) or over the decedent's remaining life expectancy (post-RBD death). Charitable bequests from the retirement account should go directly from the plan or IRA to the charity via beneficiary designation, not through the trust.

Mistake 5: Voluntary 10-year election that turns out to be wrong

For pre-RBD deaths, an EDB can elect the 10-year rule instead of stretch. Some beneficiaries make this election reflexively because the 10-year rule sounds simpler. It almost always costs money. The election is irrevocable — once made, the EDB cannot switch back to stretch. Unless the beneficiary has a specific reason to want front-loaded distributions (a tax loss carryforward that will expire, a planned Roth conversion, an anticipated high-bracket year followed by low-bracket years), the stretch is dominant.

Mistake 6: Missing the AMBT subdivision deadline (September 30)

For a Type I Applicable Multi-Beneficiary Trust, the trust must be divided into separate accounts by September 30 of the year following the account owner's death. Miss the September 30 deadline and the trust is treated as a single account, with the shortest life expectancy among the beneficiaries governing distributions — typically defaulting the disabled or chronically ill beneficiary's share into the 10-year rule alongside the other beneficiaries. This is the single most consequential deadline in the AMBT structure and the one most commonly missed by trustees who are not versed in the SECURE 2.0 mechanics.

State-tax overlay

EDB status is a federal-tax question, but many state income-tax systems modify the practical outcome. The pattern:^[12]

For deep state-specific analysis, see our companion pieces on Illinois retirement taxation and California §401(k) and IRA basis treatment.

The EDB paperwork sequence

Whatever the EDB category, the paperwork sequence is consistent. Executed in this order in the 10 months following death, the beneficiary preserves every stretch dollar available:

1. Order 4–6 certified death certificates — every custodian and financial institution will need an original or certified copy.
2. Notify the custodian of the deceased's IRA or the plan administrator of the 401(k)/403(b) within 30 days of death.
3. Obtain birth-date documentation for the beneficiary (driver's license, passport, birth certificate). For not-more-than-10-years-younger status, this is the entire qualification.
4. For disabled EDB status: gather SSDI/SSI award letter, VA disability rating, or physician certification per §72(m)(7).
5. For chronically ill EDB status: obtain a fresh physician certification per modified §7702B(c)(2), attesting to inability to perform ≥2 ADLs (or severe cognitive impairment) AND to the indefinite-and-lengthy expected duration.
6. File all documentation with the plan administrator/custodian by October 31 of the year following death. This is a hard deadline.
7. For AMBT trusts: execute the September 30 subdivision (Type I) or confirm the drafted priority language (Type II) with the trustee and estate attorney.
8. Take the year-of-death RMD in cash if the deceased had reached RBD and had not satisfied it by date of death.
9. Confirm the account title reads "IRA of [Deceased], deceased [date], for the benefit of [Beneficiary]" — the "for the benefit of" language matters for tax reporting.
10. Set up annual RMD calculations using the correct Single Life Table divisor and the correct EDB-specific convention (annual recalculation for spouse and minor child; subtract-1 for the other categories).

Action checklist

Frequently asked questions