By Sarah Brenner, JD
Director of Retirement Education
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I have read with interest, Ian Berger’s article titled “IRS Waives 50% Penalty for Missed 2021 and 2022 RMDs within the 10-Year Period.” I am glad that this is starting to be clarified by the IRS. Has any guidance been provided yet on how to calculate the future RMDs?
My father passed away in March of 2020 and I was a beneficiary of his IRA. If I had an inherited IRA with any value on Dec 31, 2021, I assume that I would not need to take an RMD in 2022 (nor in 2021.) I assume that if the value on December 31, 2022 is $100,000, I will have 8 years to take the distributions, starting in the 2023 tax year? Would the RMD be calculated at 1/8 of the balance, $12,500?
The IRS position in the proposed SECURE Act regulations that RMDs would sometimes be required during the 10-year period was a big surprise to almost everybody. In response, to help with the confusion, the IRS issued Notice 2022-53 which waived the 50% penalty for 2021 and 2022 RMDs for those affected by this rule.
This relief, while helpful, does not answer the question as to what will happen with this rule in 2023 and beyond. If the IRS sticks to its interpretation in the proposed regulations , if your father died after his required beginning date, you would need to take RMDs during years 3-9 of the 10-year period and empty the inherited IRA by the end of the 10th year. The annual RMDs would be calculated using your single life expectancy.
I contributed $7,000 into my Roth IRA account prior to January 8th of this year. I was 71 at the time and still working full time. I retired on January 8th. Reading your articles on excessive contributions, did I contribute too much money into my Roth IRA as I did not earn $7,000 for the 8 days that I did work this year? Thank you in advance for answering this question.
PS—If I did contribute too much money, do I just take it out of my Roth IRA or is there a particular form I must file?
The amount that you can contribute to an IRA for the year is limited to the lesser of the annual contribution limit ($7,000 in 2022 for those over age 50, or your taxable compensation. So, if you did not earn $7,000 and your spouse does not have any taxable compensation, then you will have an excess contribution in your IRA.
Removing an excess contribution requires a special procedure. You must remove the contribution and the net income attributable to it. The IRA custodian will report the withdrawal as a distribution of an excess contribution. Be sure to get this done by October 15, 2023, or you will be subject to a 6% penalty on the excess amount.