RMD Aggregation Rules — Multiple IRA and 401(k) Accounts
How do aggregation rules work when I have multiple IRAs or retirement accounts?
If you own multiple traditional IRAs, SEP IRAs, or SIMPLE IRAs, you must calculate an RMD for each account separately — but you can satisfy the total combined RMD by withdrawing from any one or combination of those accounts. This is IRA aggregation.
However, aggregation does NOT work across account types. Each 401(k), 403(b), or 457(b) plan must satisfy its own RMD independently. You cannot use an IRA distribution to cover a 401(k) RMD, or vice versa.
Key RMD Rules
- 1Traditional IRA aggregation: calculate each IRA's RMD separately, then take the total from any one or combination of your traditional IRAs.
- 2SEP IRA and SIMPLE IRA accounts are included in IRA aggregation alongside traditional IRAs.
- 3403(b) plans: similar aggregation allowed — calculate each 403(b) RMD separately, satisfy total from any of your 403(b) plans.
- 4401(k), 457(b) governmental plans: each plan must satisfy its own RMD — no cross-plan aggregation.
- 5Roth IRAs: no RMD required during the owner's lifetime — excluded from aggregation calculations.
- 6Inherited IRAs: aggregation is only allowed between inherited IRAs from the same decedent.
Step-by-Step: Aggregation Example with 3 IRAs
You have three traditional IRAs: $200,000, $150,000, and $100,000 (December 31 balances). You are age 76 (factor 23.7). IRA 1 RMD: $200,000 ÷ 23.7 = $8,439. IRA 2 RMD: $150,000 ÷ 23.7 = $6,329. IRA 3 RMD: $100,000 ÷ 23.7 = $4,219. Total RMD: $18,987. You may take the full $18,987 from IRA 1 alone, or split it across accounts however you prefer. The IRS only requires the total annual amount be satisfied.
Strategy: Choosing Which IRA to Withdraw From
When choosing which IRA to take your aggregated RMD from, consider: (1) Account with the lowest expected return — preserves higher-growth accounts longer; (2) Account with a specific investment you want to reduce; (3) Account nearest to a required minimum for a custodian (avoid account closure fees); (4) Gifting in kind — if you want to donate appreciated stock, take the RMD from that account. Consult a tax advisor before implementing these strategies.
Common RMD Mistakes to Avoid
- ⚠Taking the total IRA RMD from a single IRA that is different from the account it was calculated for — this is allowed, but failing to aggregate all accounts first leads to an understated RMD.
- ⚠Using an IRA distribution to satisfy a 401(k) RMD — these are separate and cannot be aggregated.
- ⚠Combining inherited IRA distributions with personal IRA distributions — inherited IRAs are separate; only inherited accounts from the same decedent can be aggregated with each other.
Related RMD Tools & Guides
Frequently Asked Questions
Disclaimer: This content is for informational purposes only and does not constitute tax or financial advice. RMD rules are based on IRS Publication 590-B and SECURE 2.0 Act provisions. Always consult a qualified tax professional or financial advisor for guidance specific to your situation. IRS rules may change; verify current requirements at irs.gov.