Beneficiary IRA – Secure Act

Hello. I’m finding conflicting information on RMDs being required in years 1-10 on a post-Secure Act inherited IRA. It looks like the February IRS/Treasury Notice says that this change in requiring them is to come, but that the Secure Act 2.0 did not mention it. Could someone please point me to where I can find the final answer to this?



The proposed Secure Act Regs require an annual beneficiary RMD in years 1-9 for 10 year rule beneficiaries, but ONLY if the owner passed on or after their RBD. The inherited IRA must be drained by the end of year 10. If the owner passed prior to their RBD, there are no annual RMDs required, just full distribution in year 10.  For affected Secure Act beneficiaries the IRS has waived any penalty if an annual  beneficiary RMD was not completed in either 2021 or 2022. Secure 2.0 does not affect this issue.



Can you please provide your source/website? We are looking for a source we can check periodically for these updates. Thank you!





Thank you. I’ve seen articles saying similar but this explains the “proposed” change, I’m wonder when/where this was signed into legislation.  



  • The Secure Act was signed in Dec, 2019, but the proposed Regs were not issued until Feb, 2022. Since then the IRS has received many negative letters about their decision regarding RMDs within the 10 year rule. See p 44 of the following proposed Reg regarding RMDs within the 10 year rule.
  • 2022-02522.pdf (federalregister.gov)


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