2016 Inherited Roth IRA Rule

Client inherited a Roth IRA from his brother (3 years older) in 2016. Was he supposed to be taking RMDs from the Inherited Roth since 2016? He hasn’t taken any money out of the account since 2016 and, if so, what does he need to do know and going forward?



Yes, annual RMDs were required, except for 2020. Suggest that he make up the 2021 and 2022 RMDs and take the 2023 RMD ASAP, and file a 5329 for each year to request the penalty waiver for 2021 and 2022. As for the 2017-2019 missed RMDs, he might wait to see if the Secure 2.0 provision for a 3 year statute of limitations based on Form 1040 can be applied retroactively for years prior to 2023, and if so they are no longer required. Secure 2.0 is not clear on that point so the IRS will have to clarify.  All distributions will be non taxable since the inherited Roth is now qualified.



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