2015 inherited IRA missed RMDs

Our new client missed distributions from her inherited IRA (2015 death) for 2022, 2023, and 2024. She was 56 when she inherited the IRA, giving her an initial life expectancy of 30.6 under the Single Life Expectancy Table for Inherited IRAs. She’s currently 65. Does she recalculate her life expectancy each year, or is the recalculation option only for spouses? If not recalculating, does she continue to use the 30.6 factor each year to calculate the distribution?



Only sole spousal beneficiaries can recalculate. Non spouse beneficiaries must reduce the divisor by 1.0 each year (non recalc).

If 30.6 was the correct divisor (2022 RMD table used to reset the divisors) for 2016, the 2022 divisor is 24.6, 23.6 for 2023 and 22.6 for 2024.

The missed RMDs should be added up and a distribution taken for the total shortfall. A 5329 and 1040X will need to be filed for 2022 and 2023 to request the penalty waiver, but the 5329 for 2024 can be added to the 2024 return with the reasonable cause explanation.

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