Year-end RMD and Withholding

I have seem a number of comments on the Forum that suggest RMD withholding is deemed to be paid equally throughout the year even if you do not take the distribution until December. The extension of the comment concludes that one need not be concerned about any penalties if one has RMD withholding in December that will ensure total tax obligation is covered. Is there some IRS reference that indicates that this is so? What is basis for comments if no specific IRS reference?



  • See § 6654(g):  https://www.law.cornell.edu/uscode/text/26/6654
  • This is also captured in the calculations on Form 2210 which, by default, subtracts withholding from tax liability before determining on a quarterly basis any underpayment on the remainder.


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