Post 2020 Inherited RMD

Can you share how the changes effect the distributions for folks who were at RMD age?

Are there penalties for not taking in 21 and 22? What is the process moving forward? Thank you for your help!



If the plan owner passed after RBD, any 10 year rule beneficiaries will have to take annual RMDs in years 1-9 according to the proposed Secure Act Regs. However, because these Regs are not yet final, the IRS stated in Notice 2022-53 that there would be no penalty if no such annual RMD was distributed in 2021 or 2022. Presumably, the IRS will finalize these Regs soon and a 2023 beneficiary RMD will be required.



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