Year-End Planning Checklist for Your Wealth Management

At Withum Wealth, we believe that a large part of long-term financial success is planning ahead. For this year-end planning guide, we have included a list of actions to consider in this uncertain market environment. In addition, we include a brief article about recent guidance from the IRS regarding Inherited IRAs. We also explain how the Secure Act 2.0 makes changes to RMDs starting in 2023.

Clarification on Inherited IRA Distributions

Recall that the first iteration of the Setting Every Community Up for Retirement Enhancement Act (Secure Act), signed into law in December 2019, redefined retirement account beneficiaries and created the now well-known yet confusing ten-year distribution rule. More recently, the IRS issued some clarity as it pertains to certain retirement plan distributions for 2023.

Since the onset of the Secure Act, there has been uncertainty about how the ten-year rule would apply to non-eligible designated beneficiaries. As a reminder, Eligible Designated Beneficiaries (not subject to the new ten-year rule) include spouses and minor children of the IRA owner, chronically ill or disabled persons, and individuals who are not more than ten years younger than the IRA owner. Therefore, non-eligible designated beneficiaries include those individuals who do not meet the criteria above and certain trusts. The original legislation seemed to imply that the inherited IRA account would simply need to be emptied by the end of the tenth year following the death of the original IRA owner. For example, if an IRA account owner died in 2021, naming her adult daughter as the beneficiary, the daughter (a non-eligible designated beneficiary) would need to empty the inherited IRA no later than December 31, 2031.

Last year, the IRS issued proposed regulations stating that RMDs may apply to non-eligible beneficiaries where the deceased IRA owner died on or after their Required Beginning Date (RBD). The RBD prior to the Secure Act was April 1st of the year following the year the IRA owner reached age 70½. The Secure Act pushed the RBD out to April 1st of the year following the year the IRA owner reached age 72, while Secure 2.0 pushed it out to age 73.

The bottom line is that non-eligible designated beneficiaries of IRA owners who died on or after their RBD are subject to annual RMDs, and the inherited IRA must be emptied by the end of the tenth year. Conversely, non-eligible designated beneficiaries of IRA owners who died before their RBD are not subject to RMDs. The IRS has yet to issue final regulations on this topic, and therefore, Notice 2023-54 further delays the enforcement of RMDs until no earlier than 2024. Thus, RMDs for this class of beneficiaries are not required in 2023, and the IRS will not enforce penalties for failure to take such RMDs. Essentially, this gives non-spousal beneficiaries of inherited IRAs another year of tax deferral while the IRS issues the final regulations.

While the RMD waiver for 2023 may sound like a welcome relief, it should be noted that the ten-year distribution period was not extended. From a tax planning perspective, it may be wise to take some level of distribution in 2023 to help spread the income tax liability over the remaining years. If not, the window to empty the inherited is just getting smaller. Suppose a non-eligible designated beneficiary inherits an IRA in 2020. The ten-year clock starts in 2021 – the first year after the year of death. If the beneficiary didn’t take a distribution in 2021, 2022, or 2023, she now must empty the account over a seven-year period.

IRS Notice 2023-54 also eliminates the need to take an RMD for IRA owners born in 1951 and provides relief for those who took their RMD between January 1 and July 31, 2023. The original Secure Act moved the RMD age from 70½ to 72, which would have required those born in 1951 to take their first RMD in 2023. However, Secure 2.0 further pushed the RMD age out to 73, meaning IRA owners born in 1951 will turn 73 in 2024, and RMDs are not required for 2023. For IRA owners who mistakenly took what they thought was an RMD in the first seven months of 2023, they will be allowed to roll the false RMD back into their IRA by September 30, 2023. This is a hard cut-off but generous in that the rollover window is normally 60 days. For instance, an IRA owner who took a false RMD as far back as January 2023 will be allowed to roll over those dollars by September 30th – effectively an eight-month rollover window.

While both iterations of the Secure Act have made navigating RMDs challenging, we expect a smoother ride going forward. The IRS should issue final guidance on the RMD portion of the ten-year rule in the near future, providing the clarity investors and beneficiaries deserve.

For questions about inherited IRAs and required minimum distributions, please contact your Withum Wealth advisor. We are here to help.

2023 Year-End Tax Planning Resources

Withum’s Year-End Tax Planning Resource Center is a one-stop-shop for annual tax planning tips for individuals and businesses, legislative and regulatory changes and other tax-saving opportunities.

Year-End Planning Checklist

Budgeting

  • Review and reassess your goals and priorities
  • Revisit your 2023 budget and prepare a budget for 2024
    • Be sure to include savings for your retirement and other goals
  • Calculate your net worth and see how it compares to your financial plan
  • Evaluate whether you have sufficient cash in your emergency fund (3-6 months’ living expenses)

Portfolio Review

  • Review your asset allocation and compare it to your targets
  • Review your capital gain situation for the year
    • Consider tax loss harvesting if you are in a high tax bracket
    • Consider realizing gains if you are in the 0% Long Term Capital Gains tax bracket

Retirement Savings

  • If you were born in 1950 or earlier, satisfy your RMDs by December 31, 2023
    • Consider using Qualified Charitable Distributions for your charitable donations
  • Review your 2023 retirement contributions for any IRA or 401(k) accounts
    • Make sure you are deferring enough to employer plans to receive the full amount of any employer match
    • Contribute to a Roth IRA if you have earned income and your MAGI is below the income restrictions:
2023 MAGI Limits Range Starts Range Ends
Single $138,000 $153,000
Married filing jointly $218,000 $228,000
  • Increase your Roth retirement account holdings without increasing your current income tax
    • If your employer’s retirement plan allows after-tax contributions and in-plan conversions, take advantage of this strategy
    • If you have no pre-tax IRA accounts, do a backdoor Roth contribution
  • Make your 2024 employer benefit elections (see below)
    • If you will be 50 or over during the year, then you are eligible to contribute additional “catch-up” amounts
  • If you are retired and not yet taking RMDs, consider completing some Roth conversions (filling up your current tax or IRMAA bracket)
  • Review the beneficiaries for all your accounts

Gifting

  • Take advantage of the $17,000 per donee annual gift exclusion in 2023
  • Consider your gifting strategy:
    • Use qualified charitable distributions if you need to take RMDs
    • Donate appreciated stock to avoid paying capital gains tax
    • Combine several years of gifting to maximize your itemized deduction
  • Consider contributing to a 529 plan

Retirement Plan Contribution Limits

Retirement Plans 2023 2024
401(k), 403(b)-402(g)(1) – Maximum employee elective deferral $22,500 $23,000
Defined Contribution Plan Total Limit (Employee + Employer) $66,000 $69,000
Solo 401k Maximum Contribution (Employee + Employer)* $66,000 $69,000
Catch-up Contribution for the plans above (age 50 or older, above annual limit) $7,500 $7,500
IRA Contribution Limit $6,500 $7,000
IRA Catch-up Contribution (age 50 or older, above annual limit) $1,000 $1,000
Roth IRA Contribution Limit $6,500 $7,000
Roth IRA Catch-up Contribution (age 50 or older, above annual limit) $1,000 $1,000
SEP IRA Maximum Contribution $66,000 $69,000
Catch-up Contribution NOT permitted NOT permitted
SIMPLE Maximum Contributions $15,500 $16,000
SIMPLE Catch-up Contribution (age 50 or older, above annual limit) $3,500 $3,500

Financial Planning In Uncertain Times

“Establish a game plan and be opportunistic.”

Many of our planning strategies can serve as an effective foundation for optimizing goals and objectives. During periods of market and/or political uncertainty, it is important not to lose sight of these foundational strategies.

  • Roth Conversions
    • Converting IRA assets to a Roth IRA allows clients to remain in control of their marginal tax bracket while shifting resources to another financial “bucket”.
      • Example: converting investments intended for long-term growth while in an unusually low-income tax bracket can be a great way to help mitigate income tax drag on portfolios and reduce future RMDs.
  • Tax Loss Harvesting (for taxpayers who are not in the 0% Long Term Capital Gains tax bracket)
    • Realize positions at a loss as frequently as possible. Losses can be carried forward indefinitely to offset capital gains and $3,000 of ordinary income.
      • Example – sell a position in an ETF to realize a $2,500 loss and reinvest in a similar ETF to keep a similar market exposure.
  • Maximize & Reallocate 401(k) Contributions
    • Plan to increase contributions for the year ahead.
      • Example – set a reminder to log in (or ask the appropriate payroll person) and increase your contribution percentage of pay to coincide with the first payroll of January.
  • Review Budget and Personal Balance Sheet
    • Reducing unnecessary spending can free up cash to save and invest. Eliminate credit card debt.
      • Example – automate savings and investments into a brokerage account and reduce discretionary spending where possible. It is prudent to ensure financial stability in case economic conditions worsen.
  • Review your Financial Plan
    • Reevaluating your financial plan on a recurring basis (perhaps annually) helps to keep your plan current.
      • Example – contact your advisor to update your plan based on changes in goals, income, and any ”what if” scenarios you would like to stress test.

Contact Us

Reach out to our Withum Wealth Management Team for guidance as year-end approaches.

Disclaimer: No action should be taken without advice from a member of the Withum Wealth Management Team because tax law changes frequently, which can have a significant impact on this guide and your specific planning possibilities.