By Ian Berger, JD
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If a 76-year-old is working full time and has a SIMPLE IRA and she does not own any of the company that sponsors the SIMPLE IRA, does she still have to take a RMD (required minimum distribution) from her SIMPLE IRA?
Yes. SIMPLE IRA owners can’t use the “still-working exception” to delay RMDs until they retire. That exception is only available to certain employees in 401(k), 403(b) or 457(b) plans. Instead, SIMPLE IRA owners must start RMDs in the year they turn age 73.
My understanding is that there is now a new rule for missed year-of-death RMDs. I believe that there is now an automatic waiver of the penalty if the year-of-death RMD is taken by the beneficiary’s tax filing deadline, including extensions.
If the beneficiary waits until the year after the year of death to take the deceased’s RMD, which tax year does that distribution fall into? I have inherited the IRA of my late aunt, who never took her 2022 RMD. If I waited until 2023 to take this RMD, do I report it on my 2022 taxes or my 2023 taxes? Is the bank going to issue me a 1099-R, and if so, which year will it be for?
Your understanding of the new year-of-death RMD rules is correct. If the year-of-death RMD is missed, the beneficiary does have until his tax filing deadline, with extensions, to take the missed RMD. Additionally, the RMD is always taxed in the year it is actually distributed (2023, in your example). The custodian will issue a 1099-R for that year.