Missed RMD Question
Hello,
Hello,
This article gives an example of a missed 2024 RMD and said it could be taken as late as December 31, 2025.
According to the regulation, this would not apply until next year:
Amended § 54.4974–1 applies for taxable years beginning on or after January 1, 2025.
Would you agree that the automatic waiver won’t apply for anyone that passed away in 2024?
Year-of-Death RMD – Deadline Extended!
In the IRS’s final regulations, the deadline to take the year-of-death RMD (and thereby avoid any penalty) is officially extended: “The final regulations extend the deadline for the beneficiary to take the missed required minimum distribution and be eligible for the automatic waiver.
Thank you.
Permalink Submitted by Alan - IRA critic on Thu, 2024-12-19 20:49
The author of the Slott report article (and neither did I) notice that this Reg has it’s own applicability date of 2025, but it’s not clear whether 2025 would apply to the year of death or to the year of extension.
Prior to the final Regs, the proposed Regs of Feb, 2022 extended the deadline from the end of the year of death to the tax due date including extensions for that year. Under those proposed Regs, the year of death RMD for a 2024 decedent would not be due until 4/15/2025 or 10/15 with an extension. Therefore, this should only be a concern if the 2024 year of death RMD cannot be completed by the above dates. If it cannot be completed until after those dates (ie later in 2025), then to be on the safe side the beneficiary should probably file Form 5329 to request waiver of the penalty for reasonable cause, which would receive an automatic approval.