2021 SECURE Act RMD

If a client missed a 2021 RMD from their inherited IRA because they didn’t realize the regs would require them to take it, is there a automatic waiver of the 50% penalty if they take it now? Has the IRS issued any guidance on this?



If the 2021 RMD calculation is affected by the proposed Secure Regs rather than prior Regs, I would wait until the Regs are final and determine if such RMD was required or will be waived due to the delay in the final Regs. As for the penalty, filing a 5329 if the RMD was due but is late will result in the penalty being waived.



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