NUA and RMDs; Taking the first Two Years of RMDs using an RMD

For Andy Ives:

I have followed your previous discussion on using the NUA to cover the RMD for your first two years.  Thank you for the clarity, but when I went to Fidelity they said they do it all the time and that the specific order wasn’t as critical as you indicated so they didn’t separate out the summed RMD total as a separate withdrawal.  But  I did receive the proper 1099Rs from Fidelity for 2023. My only question is how do I inform the IRS that 2 years of RMDs were taken from the account in 2023.  Line 5 of the 1099s is greater than the 2 years of required RMDS. Is this something I have to worry about. Is there an extra IRS form that needs to be included or does this become self explanatory to the IRS when I list the total required RMD as the sum of the two RMDs for 2022 and 2023.  I am using Turbotax to file and just don’t see any way to indicate that it is two years for RMDs.

Thanks

Bill Kempner



There is no need to document that. If you reached age 72 in 2022, then your required beginning date (RBD) for your first RMD is not due until 4/1/2023. The first dollars that are distributed in 2023 count toward that 2022 RMD and then count toward the 2023 RMD. That doesn’t need to be reported to the IRS. You should maintain a record, such as an account statement, that shows that the 2022 RMD actual distribution was done by 4/1/2023. That’s part of your substantiation, but you don’t provide it to the IRS unless they ask for it. There’s no form to complete or report to be made.

Thanks very much for the quick response. Your responses over the last year or two have been very helpful for me to understand the NUA process.   For the NUA, other than the two 1099Rs, I assume it is pretty straight forward when filing. Are there any additional forms necessary to file for the NUA that I am missing?

 

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