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1 Clark v. Rameker, 573 U.S. 122 (2014) (“In ordinary usage, to speak of a person’s ‘retirement funds’ implies that the funds are currently in an account set aside for retirement, not that they were set aside for that purpose at some prior date by an entirely different person.”)

2 IRC § 401(a)(9)(B)(iii)

3 Treas. Reg. § 1.401(a)(9)-4, Q&A-3

4 Treas. Reg. § 1.401(a)(9)-4, Q&A-5(a)

5 Treas. Reg. § 1.401(a)(9)-8, Q&A-2. Note that separate accounts must be established no later than the last day of the year following the calendar year of the account owner’s death in order for the applicable distribution period to be determined independently for each account.

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