Correcting missed lifetime RMD post-death
Good Afternoon.
I have a situation that I have not previously encountered. I am looking for guidance from the group.
FACTS:
T-IRA owner 75 dies in 2013.
Post death it’s determined the deceased missed prior year(s) RMDS.
QUESTIONS
What correction method(s) is available?
Thank you
Permalink Submitted by Alan - IRA critic on Wed, 2013-07-24 19:58
This is a good question. The IRS Regs only deal with the year of death RMD of the owner (Ref IRS Reg 1.401(a)(9)-5, Q&A 4(a). There is no mention of RMD omissions for years prior to the year of death and no other guidance that I know of despite the fact that there are likely many deceased IRA owners that never took a single RMD while living. While the IRS could pursue the 50% excess accumulation penalty for a number of years from the decedent’s estate, a beneficiary is this situation should simply complete the year of death RMD and then hope they don’t hear from the IRS, particularly if they are also an estate beneficiary.