rmd

fairly new to ed s stuff but was hoping someone could help me acclimate with a question i have. new client has dob 3-9-1949. has never taken a rmd. with the 72 rule change and the corona waiver i am thinking he is subject to none for 2019/2020, 2 rmd s for 2021 now/makeup and 1 for 2022 by the end of the year. can anyone please confirm



Mike, while 2019 was his first RMD distribution year, he is fortunate enough that the CARES Act waived that RMD if he did not take it by the 4/1/2020 RBD, and of course the 2020 RMD was also waived. Therefore, his first RMD actually delinquent is for 2021. He should make up that 2021 RMD ASAP and file a Form 5329 to request waiver of the penalty. The 5329 can be added to his 2021 return if he has not yet filed it. The 2022 RMD can be taken anytime prior to year end. Both the 2021 late RMD and the 2022 RMD will be taxable in 2022.
To be clear, the age 72 rule change did not affect him because he was born orior to 7/1/1947, however the CARES Act resulted in a waiver of his 2019 and 2020 RMDs, so he has only one late RMD to make up.



ty so much.  i was so confused with the changes and how he fell right on the line for alot of it.  i assume the fact that he was still working in 2019 and in a 401k doesnt change any of this (age wise)



I had assumed you were referring to an IRA RMD. If so, my reply is correct. His 401k RMD status does not affect the IRA RMD. Are you also asking about how a 401k RMD itself would be affected?



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