Year of Death RMD and 10 year Rule (NEDB)
A NEDB inherits an IRA in 2022 and is subject to the 10 year rule & the original IRA owner was taking RMDs. Does the NEDB have to take the 2022 year of death RMD and then the 2023 RMD is waived given this latest guidance?
Permalink Submitted by David Mertz on Thu, 2023-07-27 19:47
Yes. The SECURE Act, SECURE 2.0 Act and the latest IRS guidance did nothing to remove the requirement that the year-of-death RMD be completed by a beneficiary. The recent guidance did waive the penalty for not taking a 2023 beneficiary RMD under the 10-year rule and the proposed regulations provide an automatic penalty waiver if the beneficiary completes the year-of-death RMD by the due date, including extensions, of the beneficiary’s tax return. Completing the year-of-death RMD beyond that deadline would require making a normal request for waiver with Form 5329 as was required in the past.