Missed RMD. When to file the 5329?
If an RMD for an IRA is missed, when is the 5329 filed? Is it filed with the 10% penalty in the year a corrective distribution is made (assuming within the 2-year window), or is it filed in the year the RMD was missed?
Permalink Submitted by Alan - IRA critic on Fri, 2025-04-04 14:22
It is filed for the year the missed RMD was due, and those years are as follows:
A year of death RMD is not due until the end of the following year, and the 5329 would be filed for that following year if the deadline is missed.
A first RMD year RMD is not due until 4/1 of the following year (the RBD year). If that RMD is late the 5329 will be for that following RBD year because it was not due until that year.
In a more typical RMD situation, the 5329 is due for the year of the missed RMD.
Until the IRS slams the door, taxpayers should continue to request a full waiver for reasonable cause but the late RMD must be made up. Once the taxpayer can state that the late RMD will or has been made up, they can file the 5329 for the year of the missed RMD. However, in many of these cases, the return for the year of the missed RMD will already have been filed, therefore the 5329 will have to be filed with a 1040X (amended return) for that year.
The 5329 was changed in 2024 to reflect the new lower excise taxes and is now more complex due to the new options and is no longer designed to easily address the request for full waivers. This is a sign that the IRS may soon cut off approval of full waivers, so the sooner the 5329 can be filed the better. Nonetheless the IRS states that lines 54a and 54b can still show “RC” on the dotted line when requesting a full waiver.