Proactive Sally

If the IRA owner turned RMD age and has until 4/1 to take the RMD for the year they turned RMD age but dies on 3/31 or 4/1 without having taken any RMD, the beneficiaries don’t have to take an RMD for the year the owner turned RMD age if the person died 3/31 but does have to take the RMD for the year the person turned RMD age if they died on 4/1? Or the beneficiaries only have to take it if the person died 4/2? I know, the owner would have been cutting it close……



  • Prior to the RBD means 3/31 or before, and “on or after” means 4/1 or later. If the owner passes prior to RBD, there is no year of death RMD for the beneficiary to complete. The beneficiary’s first RMD will be for the year after the owner’s death.
  • If the owner passes on or after RBD, the beneficiary is responsible for completing the RMD for the year of death, but not for the prior year which would have been the owner’s first RMD distribution year. Ref IRS Reg 1.401(a)(9)-5, QA 4.


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