Am IRA account holder received the RMD for 2017 in early January 2018. Due to a delay by the custodian, the check was not prepared and mailed until January 8, 2018, even though it was requested in December 2017. The account holder intends to file form 5329 for tax year 2017. The question is whether to file the form 5329 now, with the 2017 tax return, or whether to wait to early 2019 when the form 1099-R is received for this distribution. In either case waiver of the penalty will be requested for reasonable cause, with “RC” entered on line 54, and showing zero as the entry in line 54. A statement will be submitted in either case to the effect that the late RMD was due to delay by the custodian, and that corrective action has been taken to schedule RMDs earlier. This will ensure that the 2018 RMD is received timely during 2018. So should the form 5329 be submitted now, with a copy of the distribution check, or should he wait to submit it until early 2019 after receiving the form 1099-R, which will also include the 2018 RMD?