Notice 2022-53 and missed RMDs

Reading this Notice with regard to relief from the RMD excise tax

Notice states that there’s no 50% penalty for “certain RMDs” that were missed in 2021/2022. Which is great, given the confusion heretofore.

But the Notice appears silent on whether those missed RMDs need to be retroactively taken in 2023.

Do those need to be taken out 2023, or can they be left in the account and just added to the balance upon which RMDs are calculated for 2023 and forward?



This should be determined when the final Regs are released. Until then, it’s anybody’s guess whether the IRS will waive these 2 years of RMDs and be content to receive the taxable income over the remaining portion of the 10 year period, or will require them to be made up in 2023. And this all assumes that these annual RMDs even survive in the final Regs, as many pundits have protested these annual RMDs. Therefore, there are 3 likely possibilities to resolve this.



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