Spousal IRA Rollover vs Inherited IRA in 2026: IRC §408(d)(3)(C), the SECURE Act 10-Year Rule, and the Surviving-Spouse Decision Framework

Every year in the United States, more than 1.5 million surviving spouses inherit a retirement account. Most of them sign whatever paperwork the plan administrator or IRA custodian puts in front of them — usually a boilerplate "beneficiary claim form" that treats the account as an inherited IRA in the survivor's name. And for a large fraction of those survivors, that default was the wrong choice.

The surviving spouse of an IRA owner or 401(k) participant occupies a unique position in the tax code. Every other beneficiary — an adult child, a sibling, a friend, a trust — is bound by the SECURE Act 10-year rule and has a fixed set of moves. The surviving spouse has at least three, sometimes four, entirely different treatments to choose from. Each has a different distribution schedule, a different early-withdrawal penalty exposure, a different set of contribution rights, and a different estate-planning outcome for the survivor's own beneficiaries.

The choice is not intuitive. The right answer depends on the survivor's age, the deceased spouse's age, whether the deceased spouse had already reached their required beginning date, how much income the survivor needs before their own age 59½, whether there are other beneficiaries splitting the account, and how big the estate is. There is no single "always do this" answer — but there is a decision framework, and this guide walks through it.

The three primary options for a surviving spouse are: (1) the spousal rollover under IRC §408(d)(3)(C) and Treas. Reg. §1.408-8, which treats the account as the survivor's own IRA;^[1] (2) the inherited IRA under IRC §401(a)(9)(E)(ii)(I) with Eligible Designated Beneficiary status, letting the survivor stretch distributions over their own single life expectancy;^[2] and (3) after 2023, the SECURE 2.0 §204 election to be treated as the deceased spouse for RMD-timing purposes, most valuable when the deceased spouse was younger.^[3] A fourth option — the disclaimer under IRC §2518, letting the account pass to contingent beneficiaries — matters less often but can save six figures in estate-tax exposure.

When you are ready to model your own numbers against your own timeline, the CalcLeap retirement calculator, the Traditional IRA calculator, and the 401(k) withdrawal calculator handle the arithmetic. This article walks through the statute, the four options in order, the RMD math under the July 2024 final regulations, three worked case studies with hand-checked numbers, and every mistake we have seen turn what should be a routine election into a lifetime tax leak.

Why the surviving spouse is different from every other beneficiary

The SECURE Act of 2019 rewrote the beneficiary rules for retirement accounts. Effective for deaths after December 31, 2019, most beneficiaries lost the "stretch IRA" — the ability to spread inherited-account distributions over their own life expectancy. IRC §401(a)(9)(H), the new operative subsection, requires the entire inherited account to be distributed by December 31 of the tenth calendar year after the year of the account owner's death.^[4] 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, 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.^[5]

The 10-year rule catches almost everyone. An adult child inheriting a parent's $2M IRA is forced to accelerate distributions into a decade, often colliding with peak-earning years and pushing the child into the 32% or 35% ordinary bracket for a decade running. The tax cost of the 10-year rule versus the old stretch is regularly six figures on accounts north of $500K.

The statute carved out five categories of Eligible Designated Beneficiaries (EDBs) at IRC §401(a)(9)(E)(ii) who keep something closer to the old lifetime-stretch treatment.^[2] The five are: (1) the surviving spouse, (2) a minor child of the decedent (only until reaching the age of majority), (3) a disabled individual, (4) a chronically ill individual, and (5) an individual not more than 10 years younger than the decedent.

The surviving spouse's carve-out is the strongest of the five. Only the surviving spouse gets both the EDB stretch option and the entirely separate §408(d)(3)(C) rollover option that treats the account as the survivor's own IRA — with all the ownership rights that carries. No other EDB category has the rollover option. A minor child, a disabled beneficiary, and a not-more-than-10-years-younger sibling can all use the single-life stretch, but they cannot convert the account into "their own" IRA the way a spouse can.

Option 1: The §408(d)(3)(C) spousal rollover

The spousal rollover is the most common choice and — for surviving spouses over 59½ who don't need the account for immediate income — usually the right one. The mechanic is straightforward. The surviving spouse either directly transfers the balance of the deceased spouse's IRA into an IRA in the survivor's own name, or (rarely) takes a distribution and re-deposits it within 60 days.

Once completed, the account is treated for all tax purposes as if the survivor had owned it all along. Specifically:^[1]

• The survivor names their own beneficiaries. The deceased spouse's contingent beneficiaries are erased. If the surviving spouse remarries and wants the new spouse or their children to inherit, the new beneficiary designation controls.
• RMDs use the survivor's own required beginning date. Under §401(a)(9)(C), the survivor's RBD is April 1 of the year following the year they turn 73 (in 2026 — moving to 75 for those born after 1959 under SECURE 2.0 §107).^[6] If the deceased spouse was already taking RMDs and the survivor is only 60, the survivor stops the RMD clock entirely for 13 more years.
• The Uniform Lifetime Table applies after the survivor's RBD, not the shorter Single Life Table. The difference between the two tables is the single largest technical advantage of the rollover option over the inherited-IRA option for age-73-plus survivors.
• New contributions are allowed. A surviving spouse who is still working can contribute earned-income deferrals to the rolled-over IRA under §219, up to the 2026 §219(b)(5) limit of $7,000 ($8,000 if 50+).^[6] An inherited IRA cannot accept new contributions.
• Roth conversions become available. Only the account owner (not a beneficiary) can execute a §408A(d)(3) Roth conversion. Rolling the account into the survivor's own name unlocks the Roth conversion ladder — the strongest single lever a healthy 60-something surviving spouse has for controlling the trajectory of taxable income across their remaining lifetime.

The rollover has one significant downside: the §72(t) 10% early-withdrawal penalty applies to any distribution taken before the survivor turns 59½. On an inherited IRA, distributions are always penalty-free under §72(t)(2)(A)(ii) regardless of the beneficiary's age.^[7] A 55-year-old surviving spouse who executes the rollover and then takes a $30,000 distribution to cover mortgage and expenses pays a $3,000 penalty that would not have applied under the inherited-IRA route.

The two-step play — inherited IRA first, own IRA at 59½ — is available and often optimal for surviving spouses under 59½. Take inherited-IRA distributions to age 59½, then roll whatever remains into the survivor's own IRA at that point. Treas. Reg. §1.408-8 Q&A-5 explicitly permits the delayed rollover; there is no deadline that closes the door.^[8]

How the rollover paperwork actually works

A direct trustee-to-trustee transfer is the correct mechanism. The custodian holding the deceased spouse's IRA re-titles the account into the surviving spouse's name, or sends a check payable to the receiving IRA custodian FBO the survivor. The surviving spouse should never take a distribution to themselves and try to re-contribute it — that path invokes the 60-day rule and the once-per-year rollover limit under §408(d)(3)(B), both of which are unnecessary and error-prone.

The Form 1099-R the custodian issues will show a Code 4 (death) distribution in Box 7. On the survivor's Form 1040, the gross amount goes on Line 4a and Line 4b shows $0 taxable with "Rollover" written in the margin, per the Form 1040 Instructions.^[9] There is no separate Form 5498 requirement beyond the receiving custodian's standard rollover reporting.

Option 2: The inherited-IRA route with EDB stretch

The inherited IRA is the default. If the surviving spouse takes no affirmative action, the account remains titled as an inherited IRA — technically "IRA of [Deceased], deceased [date], for the benefit of [Survivor], beneficiary." This is the natural landing spot for a claim form filed with the custodian.

Under the SECURE Act EDB carve-out at §401(a)(9)(E)(ii), the surviving spouse can stretch distributions over their own Single Life Table expectancy — recalculated each year using the surviving spouse's age at the start of each distribution year.^[2] This is materially different from the treatment of every non-spouse EDB, whose single-life factor is fixed at year 1 and reduced by 1 each subsequent year.

The July 2024 final regulations at Treas. Reg. §1.401(a)(9)-5(d)(1)(ii) clarify that a surviving-spouse beneficiary of an inherited IRA gets to recalculate life expectancy annually — the same "annual recalculation" the surviving spouse would get on their own IRA.^[5] Practically, the surviving spouse's inherited-IRA RMD each year uses their attained-age Single Life Table divisor, not a fixed factor decremented by one.

The inherited-IRA route is the right pick when at least one of the following is true:

1. The surviving spouse is under 59½ and needs the account for living expenses. §72(t)(2)(A)(ii) exempts death-beneficiary distributions from the 10% penalty. Rolling into the survivor's own IRA collapses that exemption — every distribution before 59½ triggers the penalty.
2. The deceased spouse was significantly older and had a large unpaid year-of-death RMD. Complete that RMD from the inherited account, then decide whether to roll the balance based on the survivor's own age.
3. There is a plan-document distribution schedule the survivor prefers. Some 401(k) plans force out inherited balances on aggressive schedules. Rolling to the survivor's own IRA immediately can preserve control.
4. The survivor may not survive long. If the survivor is themselves in poor health, keeping the account inherited (rather than rolling) preserves the deceased-spouse's original beneficiary chain — a moot point if the survivor is going to name their own beneficiaries anyway.

When the inherited-IRA route is dominated by the rollover

For a surviving spouse who is (a) over 59½, (b) does not need immediate income, and (c) is the sole primary beneficiary, the rollover almost always wins — the Uniform Lifetime Table produces a materially smaller RMD than the Single Life Table at every age past the required beginning date. On a $1M account at age 78, for example, the Uniform Lifetime factor is 22.0 (RMD $45,455) while the Single Life factor is 12.4 (RMD $80,645). The delta on that year alone is $35,190 of avoidable forced distribution — every dollar of which is currently ordinary income to the survivor.

Option 3: The SECURE 2.0 §204 election — treat as deceased spouse

SECURE 2.0 §204 added IRC §401(a)(9)(B)(iv), effective for distributions in tax years beginning after December 31, 2023.^[3] It gives the surviving spouse a third option that did not exist before: elect to be treated as the deceased employee (or IRA owner) for purposes of the RMD rules — but with the beneficiary rules from §401(a)(9)(B) unaltered for post-death distribution timing.

The election matters most when the deceased spouse was younger than the surviving spouse and had not yet reached the required beginning date. In that fact pattern, treating the account as inherited would trigger inherited-IRA RMDs immediately (or at least by year 1 following death, under the July 2024 regs).^[5] Treating the account as belonging to the deceased spouse defers the first RMD until the deceased spouse would have turned 73 — potentially deferring the first forced distribution by a decade or more.

Consider a 75-year-old surviving spouse whose 68-year-old spouse dies in 2026. Under the pre-§204 rules the survivor had to either take the inherited-IRA route (RMDs starting in 2027 under Single Life Table at age 76 factor 12.4) or roll into their own IRA (RMDs starting immediately under Uniform Lifetime factor 22.9). Under §204, the survivor can elect to be treated as the deceased 68-year-old — no RMDs required until the deceased would have turned 73 in 2031. Five years of continued deferral on a $2M account, at ~7% growth, adds $200,000 of preserved balance before RMDs even begin.

Once the §204 election is made and RMDs begin, they use the Uniform Lifetime Table with the deceased spouse's age each year — as if the deceased were still alive. This produces smaller RMDs than the Single Life Table treatment the surviving spouse would face on the inherited-IRA path.

How to make the §204 election

The election is made annually and can be revoked. For IRA accounts, it is documented via the custodian's beneficiary election form or by notation on Form 5329 with the year's tax return. For 401(k) or other qualified-plan inherited accounts, the plan administrator's election form controls. The election does not preclude a subsequent §408(d)(3)(C) rollover at any point — the surviving spouse can toggle between treatments as circumstances change. This flexibility, combined with the rollover option, is why the surviving spouse's flexibility set is unmatched in the tax code.

Option 4: The §2518 qualified disclaimer

The fourth option is not a distribution treatment but a way to opt out of inheriting entirely. Under IRC §2518, a beneficiary may make a "qualified disclaimer" of an inherited asset within 9 months of death, treating the asset as if it had passed directly to the contingent beneficiaries.^[10] For a surviving spouse whose own estate is already at or near the federal §2010(c) unified credit exemption ($15M in 2026 under the OBBBA-permanent structure), inheriting an additional $1M-$3M IRA can push the survivor's estate over the exemption and expose the marginal dollars to a 40% federal estate tax at the survivor's later death.^[11]

Disclaiming to adult children instead — where the contingent-beneficiary line runs to the children — subjects the account to the 10-year rule (adult children are not EDBs) but avoids the second-death estate-tax exposure. For very large estates the estate-tax savings dwarf the accelerated-distribution cost.

The 2026 RMD math: Single Life vs. Uniform Lifetime

The single most important number in the surviving-spouse decision is the divisor the survivor will use each year to compute their RMD. There are three tables under Treas. Reg. §1.401(a)(9)-9:^[12]

1. Uniform Lifetime Table — used by account owners (including surviving spouses who executed a §408(d)(3)(C) rollover) for post-RBD distributions.
2. Single Life Table — used by beneficiaries (including surviving spouses on the inherited-IRA route) each year.
3. Joint and Last Survivor Table — used by account owners whose sole beneficiary is a spouse more than 10 years younger; not commonly relevant to the surviving-spouse decision after first death.

The two-table delta at common surviving-spouse ages, all figures from the November 2020 IRS final regulations updated by the July 2024 amendments:^[12]

The delta compounds. Over a 20-year retirement span from 73 to 93, on a $1M account starting balance, the aggregate forced-distribution delta is more than $700,000 of additional dollars pulled out of the inherited-IRA account versus the rolled-over own-IRA — every one of those dollars taxable at the survivor's ordinary rate, and every one of them no longer available for continued tax-deferred growth or heirs.

This is the fundamental math case for the rollover option among older surviving spouses. It is also why the §204 election matters when the deceased was younger: it defers the RMD clock while still eventually landing on Uniform Lifetime figures.

The year-of-death RMD and the sequencing rule

If the deceased spouse had already reached the required beginning date (age 73 in 2026 under the SECURE 2.0 §107 phase-in) and died before satisfying the calendar year's RMD, the surviving spouse (or other beneficiary) must complete that RMD by December 31 of the year of death.^[13] The dollar amount is computed from the deceased spouse's own account balance and Uniform Lifetime factor as of the last valuation before death.

The year-of-death RMD is a hard constraint. It cannot be rolled over — the amount is a required distribution and by definition is not eligible for rollover treatment under §402(c)(4)(B). A surviving spouse who intends to execute a §408(d)(3)(C) rollover must first take the year-of-death RMD in cash, then roll the remaining balance into their own IRA.

Getting this wrong triggers the SECURE 2.0 §302-reduced excise tax on the missed RMD amount. Under IRC §4974, the tax is 25% of the shortfall (down from 50% pre-SECURE 2.0), or 10% if the shortfall is corrected within a two-year correction window and Form 5329 is filed acknowledging the correction.^[14]

Roth IRA inheritance: a different playbook

Roth IRAs follow the same beneficiary-election framework, but with two important differences that reshape the analysis.^[15]

First, Roth IRAs have no lifetime required minimum distributions for the original owner. IRC §408A(c)(5) exempts Roth IRAs from the §401(a)(9)(A) RMD rule during the owner's lifetime. This means the choice between rolling into the survivor's own Roth vs. keeping as inherited Roth has NO impact on lifetime RMDs — because there are none either way for the surviving spouse rolling into their own Roth. On the inherited-Roth path, RMDs still apply (though not on ordinary-income terms).

Second, qualified Roth distributions are federal-income-tax-free. A surviving spouse who inherits a Roth IRA can typically pull the money out with no federal tax owed regardless of the treatment elected — as long as the deceased spouse's account was open at least five years and either the surviving spouse is 59½+ or one of the other §408A(d)(2) qualified-distribution exceptions applies (including death of the account owner, which always applies here).

The combination — no lifetime RMD, no tax on distribution — makes the surviving-spouse Roth decision almost purely mechanical: roll into own Roth IRA. The rollover preserves the tax-free character, eliminates any RMD exposure entirely for the survivor's lifetime, and passes on to the survivor's beneficiaries the option to do their own inheriting.

The one exception: a surviving spouse under 59½ who might need to withdraw earnings before 59½ from the inherited Roth might prefer the inherited-Roth-IRA route temporarily. Distributions from an inherited Roth are not subject to §72(t), so earnings can come out penalty-free (but ordinary-income-tax-liable if the 5-year clock isn't satisfied). Once the survivor hits 59½, the rollover into own Roth becomes strictly dominant.

Three worked case studies

Case study 1: Priya, 52, husband Nikhil dies at 71 with $1.6M Traditional IRA

Priya is 52, employed as a school administrator earning $95,000. Her husband Nikhil dies at 71 with a $1.6M Traditional IRA. Nikhil had not yet reached his required beginning date (which for him would have been April 1, 2029 — age 73 under SECURE 2.0). Priya is the sole primary beneficiary; the two adult children are contingent.

Priya's constraints: she is 7.5 years shy of 59½, the family has $340,000 remaining on their mortgage, and both children are in college with tuition still due. She needs $40,000 per year from the account over the next 7.5 years to cover the tuition-and-mortgage gap.

The right answer: inherited-IRA route now, with rollover to own IRA at 59½.

Under the inherited-IRA path, Priya's annual distributions are exempt from §72(t) — $40,000 × 7.5 years = $300,000 pulled out penalty-free between ages 52 and 59.5. If she had rolled to her own IRA instead, that same $300,000 would have triggered a $30,000 §72(t) penalty on top of the ordinary income tax.^[7] Assuming Priya's marginal bracket is 22% during those years, the total tax delta between the two paths is $30,000 in penalty savings — a real, tangible, avoidable cost.

At age 59.5, Priya rolls the remaining ~$1.35M (after distributions and market growth) into her own Traditional IRA. From that point forward, she can (a) name her own beneficiaries, (b) execute Roth conversions if she wants to control her retirement-year tax profile, and (c) use the Uniform Lifetime Table for RMDs starting at 73. Between 59.5 and 73, she has 13.5 years of no forced distributions.

Alternative considered: the §204 election to treat as Nikhil. Rejected because Nikhil was younger; his hypothetical RBD (age 73) is only one year later than Priya's. The gain is trivial. The rollover pathway with delayed execution captures nearly all the same benefit.

Case study 2: David, 62, wife Rachel dies at 60 with $2.4M Traditional IRA + $400K Roth

David is 62, retired. Rachel dies unexpectedly at 60, leaving a $2.4M Traditional IRA and a $400K Roth IRA. Rachel had not reached her RBD. David has no need for the accounts for cashflow — his own retirement savings and Social Security cover his lifestyle. His goal is to maximize the balance that eventually passes to their two adult children.

The right answer for the Traditional IRA: the SECURE 2.0 §204 election.

David is older than Rachel. Under the §204 election, David is treated as Rachel for RMD-timing purposes. Rachel's RBD would have been April 1, 2039 (age 73). No RMDs are required until then — 13 years of continued deferral. Under a straight rollover into David's own IRA, RMDs would begin at David's age 73 in 2037 — two years earlier. Under the inherited-IRA route, RMDs would begin in 2027 under the Single Life Table with David as beneficiary at age 63 (divisor 24.5). The §204 election dominates.

Assuming 7% real growth and a starting balance of $2.4M, the §204 election preserves an additional ~$375K of balance versus a straight rollover, and ~$780K of balance versus the inherited-IRA route, measured at David's own age 73.

The right answer for the Roth IRA: straight rollover into David's own Roth.

The Roth analysis is mechanical. David has no lifetime RMD exposure on his own Roth (§408A(c)(5)). Rolling the $400K into his own Roth gives him the maximum flexibility, no forced distributions during his life, and preserves the full balance for his children's inherited-Roth stretch.

Case study 3: Marcus, 74, wife Elena dies at 76 in RMD year with $3M Traditional IRA

Marcus is 74, retired. Elena dies in July at 76, mid-year, with a $3M Traditional IRA. Elena had a required minimum distribution for the year that she had not yet taken — her Uniform Lifetime divisor at 76 was 23.7, and her opening balance was $3.05M, giving a year-of-death RMD of $128,691. Marcus is the sole beneficiary; two adult children are contingent.

Step 1: Marcus, as beneficiary, must complete Elena's year-of-death RMD by December 31 of the year of death. He takes $128,691 in cash from the inherited account — reported as a Code 4 distribution on Form 1099-R, and included on Marcus's Form 1040 Line 4b as ordinary income.^[13]

Step 2: After the year-of-death RMD is complete, Marcus executes a §408(d)(3)(C) rollover of the remaining ~$2.87M into his own Traditional IRA. From next year forward, his RMDs will use the Uniform Lifetime Table with Marcus's own age. At 75 (next year) the divisor is 24.6, so his RMD would be ~$116,600 — versus ~$187,500 if he had chosen the inherited-IRA route (Single Life divisor 14.1 at age 75).

The delta over 15 years of RMDs starting at 75, assuming 6% growth net of distributions, is roughly $850,000 of preserved balance — every dollar of which either continues to compound tax-deferred or passes at Marcus's death to his adult children under the SECURE Act 10-year rule.

Alternative considered: §204 election. Rejected because Elena had already reached her RBD; the election would provide no deferral benefit. The straight rollover after year-of-death-RMD completion is the winning move.

Five surviving-spouse mistakes that permanently cost money

Mistake 1: Rolling before 59½ when the survivor needs the income

The single most common expensive mistake. A 53-year-old surviving spouse fills out the boilerplate "roll into my own IRA" form because it feels simpler, then discovers 6 months later that every distribution to cover expenses is triggering the 10% §72(t) penalty. On $50,000/year for 6 years, the avoidable penalty is $30,000. There is no undo — once the rollover happens, the account is subject to §72(t).

Mistake 2: Missing the year-of-death RMD before rolling

A surviving spouse whose spouse died in July at age 78 rolls the entire balance into their own IRA in September — including the deceased spouse's unpaid year-of-death RMD. The IRS position: the year-of-death RMD amount was never eligible for rollover in the first place. The result: a §4974 excess-contribution taint on the receiving IRA (correctable via §408(d)(4) withdrawal by the due date), plus the §4974 excise tax on the missed year-of-death RMD (25%, reducible to 10% within the correction window).^[14] Both problems compound headache. Take the year-of-death RMD in cash first, always.

Mistake 3: Ignoring the §204 election when the deceased was younger

A surviving spouse who is 75 and inherits a $1M IRA from a 65-year-old spouse takes the inherited-IRA route and starts Single Life Table RMDs at age 76 (divisor 12.4, RMD $80,645 on year-1 balance). Under the §204 election, no RMDs would be required until the deceased would have turned 73 — 8 more years of full deferral, giving the survivor time to plan Roth conversions or executing the rollover once market conditions favor. The forgone benefit compounds to more than $200,000 of preserved balance over the survivor's likely retirement horizon.

Mistake 4: Naming non-spouse co-beneficiaries and losing the sole-beneficiary EDB status

A deceased spouse names the surviving spouse and two adult children as co-beneficiaries, each entitled to 1/3. The surviving spouse's 1/3 loses the sole-beneficiary treatment. Unless separate account treatment is elected by December 31 of the year following death — via a partition on the custodian's books — the surviving spouse's share defaults to the 10-year rule under §401(a)(9)(H).^[4] Even after separate accounts, the surviving spouse's ability to execute the §408(d)(3)(C) rollover is intact, but the default drift is expensive.

Mistake 5: Accepting a partial distribution then attempting a §2518 disclaimer

A surviving spouse whose estate is over the $15M OBBBA-permanent exemption at 2026 levels wants to disclaim the inherited IRA to keep the balance out of the survivor's own estate.^[11] But they took a $20,000 distribution to cover the deceased spouse's medical bills two months before consulting an estate attorney. Under IRC §2518(b)(3), accepting any interest or benefit from the property invalidates the qualified disclaimer for the entire account. The full IRA now stays in the survivor's estate and, at the second death, adds $1M+ to the survivor's federal estate tax exposure at 40%. Wait to distribute until the disclaimer decision is documented.

State-tax overlay

The surviving-spouse decision is a federal-tax question, but many state income-tax systems modify the federal treatment. The pattern:^[16]

For deep state-specific analysis, see our companion pieces on Illinois retirement taxation, and the state-specific 401(k) treatment guides for California, New Jersey, and Pennsylvania.

The paperwork sequence

Whatever the elected route, the paperwork sequence is consistent. Executed in this order, the surviving spouse avoids every common pitfall:

1. Obtain certified death certificates — every custodian, plan administrator, and financial institution will require an original or certified copy.
2. Notify the custodian of the deceased spouse's IRA (or the plan administrator for a 401(k)) within 30 days of death.
3. Confirm beneficiary designation on file. Custodian records govern — not what the will says.
4. Confirm the year-of-death RMD status. If the deceased had reached RBD, compute the RMD from last-valued balance and Uniform Lifetime factor, plan to take it before December 31.
5. Choose the treatment — spousal rollover, inherited IRA, or §204 election. Consult with a CPA or an Enrolled Agent. Model the numbers.
6. Complete the year-of-death RMD in cash if applicable, before any rollover.
7. Execute the elected treatment via the custodian's forms — trustee-to-trustee transfer for the rollover, retitling for the inherited IRA, election form for §204.
8. Update beneficiaries on the survivor's own IRA (if rolled) — including contingent beneficiaries. Do this immediately after the rollover.

Action checklist

Frequently asked questions