IRS notice 2022-53

I am aware IRS notice 2022–53 waves the 50% penalty for certain required minimum distributions.

However I cannot seem to get a definitive answer whether 2021 and 2022 RMD’s are due for inherited retirement accounts in which the beneficiary is subject to the 10 year pay out. I’ve read some columns where the author says it is unclear and we are awaiting additional IRS guidance. Whereas other articles imply the 2021 and 2022 RMD’s are still required.

I am hoping someone on this board can clarify

Thank you in advance



It all depends on whether the commenter assumes the IRS proposed Regs on this matter will be included in the final Regs as is, or whether the IRS might once again change their mind and not require these annual RMDs within the 10 year rule. If the Regs are approved as submitted last February, the annual RMDs within the 10 year rule will be required if the owner passed on or after their RBD. For deaths prior to RBD, there is no question that such annual RMDs will not be required. 

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