RMD

Taxpayer failed to take full RMD prior to death in 2018. Non-spouse beneficiary discovered the shortage.
Beneficiary had difficulty with IRA custodians and was not able to take the balance of decedents RMD until March of 2019. Which tax return(s) should file 5329 to request waiver of penalty? Decedent 2018 1040?, Beneficiary 2018 1040?, both? Beneficiary will report balance of decedent’s 2018 RMD and 2019 RMD on his 2019 1040.
Any guidance would sure be appreciated.



  • Because the beneficiary became responsible for completing the decedent’s 2018 RMD upon the death of the decedent, the beneficiary’s 2018 tax return must include the Form 5329 requesting the waiver.  Follow the instructions on the last page of the instructions for Form 5329, Waiver of tax.  Requesting a waiver on the entire amount of the late-taken shortfall will result in lines 54 and 55 having zeros, so no penalty is to be paid with this form.  Include an explanation statement providing the reasonable explanation that you mentioned above.
  • The distribution itself is reportable on the beneficiary’s 2019 tax return as you mentioned.

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