Still waiting, since the IRS proposed Secure Act Regs are not final. For the last 3 years, the IRS has waived the penalty for not taking beneficiary RMDs in years 1-9 of the 10 year rule. According to the past pattern, if the IRS has still not finalized the proposed Regs by fall, they will also waive the penalty for the 2024 beneficiary RMDs in this situation.  A beneficiary who prefers not to take a 2024 RMD might wait to see if the IRS waives the penalty later this year or not, because a distribution taken earlier cannot be rolled back. That said, every year that a distribution is not taken (RMD or otherwise) results in larger distributions for later which might spike the marginal rate in these later years. 

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