Missed RMD & Form 5329
We have a client who missed their RMD for 2018. They’ve since taken the RMD and we’ve advised them to complete Form 5329 to notify the IRS of the missed RMD. Their CPA is not familiar with this tax form. Based on the form instructions, it seems that Form 5329 can be filed along with the 2019 tax return, as that’s the year the distribution is being processed, or it can be filed for tax year 2018 as a stand alone form. I assume this has to be filed for 2018 or ASAP, basically, to start the statute of limitations, but am having trouble finding a concrete answer from the IRS. Can anyone confirm what tax year the 5329 should be filed for in a missed RMD situation? Thanks!
Permalink Submitted by Alan - IRA critic on Wed, 2019-03-20 16:20
The 5329 edition is the year for which the RMD is delinquent (2018). There are only 4 lines, but completing the form properly is not intuitive. The last page of the 5329 Inst. should be read before completing the form. The 2018 5329 can be sent in alone if the 2018 tax return has already been filed. The make up distribution will be taxable in 2019, the year it was actually distributed. The CPA should obviously be familiar with this form though.