non-spousal inherited IRA – 2020 decedent

I have a non-spousal beneficiary who inherited her Mother’s IRA – she was age 82 at her death in 2020. I have seen a post from the American Banker Association that reports RMDs for 2021 & 2022 are waived for such a beneficiary (i.e., those subject to teh new 10-year rule). However, I can find no cites in either the Federal register nor the IRS web site affirming as such. It was identified as transition relief granted by the IRS. I’d like a bit more assurance than just an article if anyone can help. Thank you!



  • Link to Notice 2022-53. While these RMDs for two years are not required to be distributed in these years, we think that the IRS will allow recovery of these RMDs through larger annual RMDs for the rest of the 10 year rule period, and will not require that they be made up entirely in 2023. 
  • N-2022-53 (irs.gov)

Alan:  Thank you so much!!

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