Splitting first RMD across tax years

Had a question/situation today that I’ve not encountered before:

Your first RMD can come out as late as April 1st of the year after the year you turn 70.5 (setting aside SECURE changes for now).

But is there a code section/rule/reg/proc that says you must take all of that first RMD in a single tax year? In other words, are you unable to take some of 2019’s RMD in 2019 and the rest of it in 2020 by April 1?

I know that splitting like that might be a hassle from an accounting standpoint, as the untaken portion of 2019’s RMD will be included in the 2019 year-end balance, thus (slightly) jacking up your 2020 RMD, but is it prohibited by the IRC/IRS?

Please and thank you!



The 2019 RMD can be deferred in whole or in part to 4/1/2020. The only requirement in the tax code is that the entire 2019 RMD is completed by then. Taking part of the RMD in 2019 should not result in any hassle, as the taxpayer need only determine the amount of the remaining portion and be sure it is distributed by 4/1. No adjustment is made to the actual 12/31/2019 balance, as the 2020 RMD will be calculated directly from the balance with no adjustments required.

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