2021 and 2022 RMD – Bene on 10yr rule

As you know, we were under the impression that the 10yr rule meant that the bene didn’t have to take an annual RMD but w/draw the account by the 10th yr. It was since then brought to our attention that bene’s would have to take an annual RMD if the IRA owner passed after their RBD. Because of this, we have numerous clients who did not take a 2021 RMD and still haven’t taken a 2022 RMD. We heard that the 50% penalty has been waived but no confirmation that the bene’s have to w/draw their 2021 RMD and I’m assuming they would have to take their 2022 RMD?

Can you please clarify this?



Would like to, but the IRS has not clarified this. They only stated that there would be no penalty for 2021 or 2022 beneficiary RMDs. When the final Regs are released the IRS could just require these RMDs to begin in 2023, with or without making up the 2021 and 2022 RMDs. It is also possible that due to recommendations submitted to them, that they return to just the 10 year rule with no annual RMDs.

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