Year-of-Death RMDs: Rules for a Surviving Spouse and Beneficiaries

A required minimum distribution is not automatically due in every year an IRA owner dies. The first question is whether the owner died before or on or after the owner’s required beginning date.

• If the owner died before the required beginning date, there is generally no owner RMD for the year of death.
• If the owner died on or after the required beginning date, the beneficiaries are generally responsible for distributing any part of the owner’s year-of-death RMD that the owner had not already taken.

That year-of-death calculation is separate from the beneficiary’s own post-death distribution schedule. A surviving spouse may have choices that are unavailable to a child, trust, estate, or other beneficiary. The account type and plan document also matter.

“The owner had reached RMD age” is not a complete answer. Confirm the required beginning date, account type, actual distributions, and beneficiary status for each account.

The answer-first workflow

For every retirement account, create one row and resolve these facts in order:

1. Is it a traditional, SEP, SIMPLE, Roth, 401(k), 403(b), governmental 457(b), pension, annuity, or other plan?
2. What was the owner’s date of birth, retirement status, ownership percentage in an employer, and required beginning date under the law applicable to that account?
3. Did death occur before or on or after that required beginning date?
4. What was the owner’s RMD for the year of death?
5. How much qualifying distribution did the owner receive before death?
6. What unpaid year-of-death amount remains?
7. Who is the beneficiary of record for this specific account?
8. Who will take the remaining amount, from which account, and by what deadline?
9. What post-death rule applies beginning in the following year?
10. Was anything missed, and what correction and Form 5329 work is required?

Do not combine account balances or distributions until an adviser confirms that the governing aggregation rule permits it.

Required beginning date is a legal term

The required beginning date is not always the owner’s birthday and is not identical across every retirement arrangement.

For traditional, SEP, and SIMPLE IRAs, an owner generally must begin RMDs under the age rules applicable to the owner’s birth year. The first distribution year can have a deadline extending to April 1 of the following year, although later-year RMDs generally remain due by December 31. Delaying the first payment can place two taxable RMDs in one calendar year.

For many workplace plans, a participant who is not a more-than-5% owner may be able to delay the required beginning date until retirement if the plan permits. A more-than-5% owner follows a different rule. Older deaths and older birth years can be governed by earlier statutory ages.

The custodian’s statement that the owner was “in RMD status” is useful evidence, but obtain the actual calculation and legal start date. A plan’s required distribution can also be more restrictive than the minimum tax rule.

Determine whether an owner RMD existed in the year of death

Death before the required beginning date

IRS Publication 590-B states that if an IRA owner died before the required beginning date, there is no owner RMD for the year of death. The beneficiary rules begin after death; they do not retroactively create an owner RMD in the death year.

This point prevents an unnecessary withdrawal. Do not order a “final RMD” simply because the owner was elderly or because a custodian’s system generated an estimate. Confirm the required beginning date first.

Death on or after the required beginning date

If the owner died on or after the required beginning date, calculate the owner’s RMD for that calendar year and subtract distributions the owner actually received that count toward it. The beneficiaries are responsible for distributing the remaining amount.

Suppose an owner’s RMD for the death year was $80,000 and $30,000 had been distributed before death. The unresolved owner RMD is $50,000. That is not the beneficiary’s lifetime or 10-year distribution for the next year; it is completion of the deceased owner’s existing death-year requirement.

Do not assume an automatic monthly withdrawal completed the requirement. Payments may have stopped, the final debit may have been rejected, or the owner may have taken distributions from an account that cannot satisfy this account’s RMD.

Build the account-by-account ledger

Use a table that can be signed off by the custodian and tax preparer:

Field	Evidence
Plan or IRA legal name	Plan document or custodial agreement
Account type and tax character	Year-end statement and plan confirmation
Owner and tax identification number	Account registration
Beneficiary and contingent beneficiaries	Beneficiary designation on file at death
Owner date of birth and date of death	Vital records
Required beginning date	Written adviser or plan calculation
Prior December 31 balance	Custodian statement
Death-year RMD	Custodian worksheet independently reviewed
Death-year distributions before death	Transaction history and Forms 1099-R
Remaining owner RMD	Reconciliation
Post-death account title	New registration confirmation
Beneficiary classification	Legal and tax review
Next deadline and method	Written distribution calendar

Include accounts at former employers, brokerage firms, banks, insurance companies, and government plans. Search prior tax returns for Forms 1099-R and 8606, retirement statements, benefit elections, and qualified charitable distribution records.

Who reports the remaining year-of-death distribution?

A distribution made after death generally belongs to the recipient who receives it (the beneficiary, estate, or trust)not to the decedent’s final Form 1040 merely because it completes the decedent’s RMD calculation. Taxable retirement distributions after death are generally income in respect of a decedent.

The payer should issue Form 1099-R under the recipient’s correct name and taxpayer identification number. Verify:

• gross distribution;
• taxable amount or “taxable amount not determined” indicator;
• distribution code;
• federal and state withholding;
• payer and plan identification; and
• recipient information.

If the payer used the decedent’s Social Security number after death, obtain tax advice and request correction. Do not report the same distribution on two returns to make the information forms appear to reconcile.

The RMD itself cannot be rolled over

An amount required to be distributed is generally not an eligible rollover distribution. That matters when a surviving spouse plans a spousal rollover or treats an inherited IRA as her own.

Before moving the account, identify and distribute the unpaid owner RMD. Do not include it in the rollover check or trustee transfer. If a custodian already moved the full balance, ask the custodian and tax adviser how the year-of-death requirement will be satisfied and documented.

The RMD is usually taxable to the recipient except to the extent the account contains recoverable basis or the distribution is otherwise tax-free. Obtain the decedent’s Forms 8606 and plan basis records. Withholding is a payment toward tax, not a reduction of the RMD amount for reporting purposes.

Surviving spouse choices after the death year

A surviving spouse who is the sole beneficiary commonly has more options than any other beneficiary. Depending on the account and facts, she may be able to:

• keep an IRA titled as an inherited IRA and take beneficiary distributions;
• elect special surviving-spouse treatment under current rules;
• treat the IRA as her own;
• roll eligible amounts to her own IRA or an eligible plan; or
• take distributions under the applicable inherited-account schedule.

These choices can change the start date, life-expectancy factor, early-distribution treatment, creditor protection, successor-beneficiary result, and flexibility. A younger surviving spouse who may need funds before age 59½ can have a different best answer from an older spouse seeking maximum deferral.

Do not retitle or roll the account solely because “spouses can roll over.” First model:

• the decedent’s and spouse’s ages;
• whether the decedent died before the required beginning date;
• the spouse’s need for near-term access;
• account basis and Roth status;
• successor beneficiaries;
• plan-specific deadlines and options;
• state creditor and property law; and
• the spouse’s own RMD timetable.

Read Inherited Retirement Accounts: The Spousal Options before signing the custodian’s election.

Beneficiary classifications drive later years

The SECURE Act framework and final RMD regulations divide beneficiaries into categories. The category must be established under the beneficiary designation and applicable documentation, not assumed from family relationship.

Eligible designated beneficiary

Eligible designated beneficiaries can include a surviving spouse, the owner’s minor child, a disabled or chronically ill individual meeting the statutory definitions, and an individual not more than 10 years younger than the owner. Life-expectancy treatment can be available, with additional rules and a later 10-year period in some circumstances.

The owner’s minor child category is not a generic exception for every minor beneficiary. Disability and chronic-illness status require timely and adequate documentation under applicable rules.

Designated beneficiary who is not eligible

Many adult children and other individuals are designated beneficiaries but not eligible designated beneficiaries. The 10-year rule generally requires the account to be emptied by December 31 of the year containing the tenth anniversary of death.

If the owner died on or after the required beginning date, annual RMDs generally continue during years one through nine as well as full distribution by the end of year ten. The final regulations apply this annual requirement beginning with 2025 distribution years, after earlier transition relief.

If the owner died before the required beginning date and the 10-year rule applies, current Publication 590-B generally does not require a distribution before year ten. “No annual minimum” does not mean waiting is always tax-efficient; it means the beneficiary can model distributions across the window.

Beneficiary that is not an individual

An estate, charity, or nonqualifying trust is not a designated individual beneficiary. Depending on whether death occurred before or after the required beginning date, a five-year rule or remaining-life-expectancy rule may apply. A properly structured qualifying trust can be analyzed differently.

Trust beneficiary rules depend on the trust text, beneficiaries, documentation, and deadlines. Do not treat every trust as a person or every see-through trust as eligible for the same schedule.

Roth accounts still need a beneficiary analysis

A Roth IRA owner has no lifetime RMD. Current federal rules also removed lifetime RMDs from designated Roth accounts in 401(k) and 403(b) plans. But after the owner’s death, beneficiary distribution rules apply to inherited Roth arrangements.

The income-tax character and RMD schedule are different questions. A qualified Roth distribution may be income-tax-free while still being required under a beneficiary timetable. The five-year holding rule and any nonqualified earnings component also need review.

Do not omit a Roth account from the estate inventory or beneficiary calendar because the owner had no lifetime RMD.

Account aggregation is limited

The rule allowing several IRA RMDs to be taken from one IRA is often overextended.

• An owner generally calculates the RMD separately for each traditional IRA but may aggregate qualifying traditional IRA amounts and take the total from one or more of those IRAs.
• SEP and SIMPLE IRAs generally participate in IRA aggregation under applicable rules.
• Inherited IRAs generally can be aggregated only within permitted groups, including accounts inherited from the same decedent with compatible characteristics.
• Inherited Roth IRAs have their own aggregation group.
• Multiple 403(b) accounts may have a permitted aggregation rule.
• A 401(k) or other qualified plan generally must satisfy its RMD from that specific plan; one plan’s withdrawal does not satisfy another plan’s requirement.

Do not use a distribution from the widow’s own IRA to satisfy the decedent’s inherited-account RMD. Do not use one spouse’s RMD to satisfy the other spouse’s requirement. Obtain a written aggregation map before consolidating accounts.

Coordinate the deadline with tax planning

The unpaid owner RMD generally must be distributed by December 31 of the year of death. If that date is missed, the final regulations (Treas. Reg. §54.4974-1(g)(3), for taxable years beginning in 2025 or later) automatically waive the excise tax when the beneficiary takes the shortfall by the later of the due date, including extensions, of the beneficiary’s return for the death year or December 31 of the following year. Begin well before year-end because beneficiary certification, account retitling, estate appointments, medallion guarantees, and custodian review can take weeks.

A late-year death can leave little operating time. Send a written urgency request to each custodian that states the date of death, asks whether an owner RMD existed, requests the full calculation and distribution history, and asks what documentation is required to complete it.

RMD income can interact with:

• estimated tax and withholding;
• capital gains and loss harvesting;
• Roth conversions;
• charitable giving;
• net investment income tax;
• taxation of Social Security benefits;
• Medicare income-related premium adjustments;
• state income tax; and
• trust or estate tax brackets.

Completing the legal minimum is the first task. Then model whether a larger distribution is useful. An excess distribution generally cannot be carried forward to reduce a later year’s RMD.

Qualified charitable distributions require separate eligibility

A qualified charitable distribution can count toward an IRA owner’s RMD when all current QCD requirements are met. It is not available merely because the decedent previously used it.

After death, the beneficiary must independently satisfy the age and account requirements, and payment must go directly from the eligible IRA to an eligible charity. A distribution paid to the beneficiary and then donated is not converted into a QCD. Estates and trusts should not assume they can use an individual’s QCD rule.

If a pre-death QCD was in process, verify whether it was completed, whether the charity received it, and how the custodian reported it. Keep the charitable acknowledgment and custodian evidence.

If an RMD was missed

Do not wait for a notice. First calculate the exact shortfall account by account and take the corrective distribution as soon as professional advice confirms the amount.

Under current Form 5329 instructions, the additional tax on an excess accumulation is generally 25% of the shortfall. It may be reduced to 10% when the shortfall is corrected and the required return reflecting the tax is submitted within the correction window.

The correction window ends on the earliest of:

• mailing of a deficiency notice concerning the tax;
• assessment of the tax; or
• the last day of the second taxable year beginning after the taxable year in which the additional tax was imposed.

The IRS can waive some or all of the tax when the shortfall resulted from reasonable error and reasonable steps are being taken to remedy it. A waiver is requested through Form 5329 with the prescribed “RC” notation and an explanatory statement. Relief is not automatic; the IRS decides whether to grant it. The exception is the decedent’s unpaid death-year RMD: when the beneficiary completes it within the extended period described above, the final regulations waive the tax automatically, without a reasonable-cause request.

Build a correction file

Include:

• death certificate and appointment evidence;
• account and beneficiary records;
• required beginning date analysis;
• original and corrected RMD calculations;
• distribution histories;
• evidence of efforts to contact custodians;
• documentation of processing delays or errors;
• corrective distribution confirmation;
• Form 1099-R;
• Form 5329 and reasonable-cause statement; and
• proof of filing and any payment.

Use the version of Form 5329 for the year of the missed RMD. If the responsible taxpayer is an estate or trust, coordinate reporting with Form 1041 instructions.

Custodian answers to obtain in writing

For each account ask:

1. What required beginning date did you apply and why?
2. Was an owner RMD due for the death year?
3. What prior year-end balance and life-expectancy table did you use?
4. What was the calculated owner RMD?
5. Which distributions counted before death?
6. What balance remains unpaid?
7. Which beneficiary or fiduciary can request it?
8. How will the distribution and withholding be reported?
9. What post-death title and beneficiary classification are in your system?
10. What deadlines and plan restrictions apply next year?
11. Can any accounts legally be aggregated?
12. What forms and processing time are required?

A custodian can administer its product, but it does not replace tax counsel. Ask the tax preparer to review the custodian’s calculation, especially when the plan, employment status, beneficiaries, or required beginning date is unclear.

Common mistakes

• Assuming every elderly decedent owed a death-year RMD.
• Assuming death canceled an unpaid RMD after the required beginning date.
• Using “RMD age” instead of calculating the required beginning date.
• Counting a distribution that was scheduled but never completed.
• Rolling the unpaid owner RMD into the spouse’s IRA.
• Reporting a post-death distribution on the decedent’s final return without recipient analysis.
• Applying a spouse option to a trust, estate, child, or other beneficiary.
• Believing the 10-year rule always permits nine years without distributions.
• Believing inherited Roth accounts have no beneficiary distribution rules.
• Satisfying a 401(k) RMD from an IRA or another employer plan.
• Combining inherited accounts from different decedents.
• Treating a corrective distribution as eliminating Form 5329 work automatically, outside the death-year automatic waiver.
• Waiting for the custodian to identify all accounts and deadlines.

Frequently asked questions

Is an RMD always due in the year someone dies?

No. If an IRA owner dies before the required beginning date, there generally is no owner RMD for the year of death. If death occurs on or after the required beginning date, beneficiaries generally must complete any unpaid owner RMD.

Who takes the unpaid year-of-death RMD?

The beneficiary or beneficiaries are generally responsible. The actual recipient and allocation can depend on the account registration, beneficiary designation, plan terms, and estate administration. Obtain the custodian’s procedure and tax advice in writing.

Can a surviving spouse roll over the whole account first?

The RMD itself generally cannot be rolled over. Identify and distribute the unpaid owner RMD before completing a spousal rollover or own-IRA election. Model the spouse’s inherited-versus-own treatment before retitling.

Is the year-of-death RMD reported on the final Form 1040?

Amounts received by the owner before death can appear on the final return. A distribution paid after death generally belongs to the beneficiary, estate, or trust that receives it and is generally income in respect of a decedent. Reconcile Form 1099-R recipient information.

Does the 10-year rule require annual withdrawals?

If the owner died on or after the required beginning date, a non-eligible designated beneficiary generally must take annual RMDs and empty the account by year ten. If the owner died before the required beginning date, the general 10-year rule does not require annual distributions before the final deadline. Exceptions and special categories require review.

Do inherited Roth IRAs have RMDs?

Beneficiary distribution rules apply after a Roth owner’s death even though the owner had no lifetime Roth IRA RMD. The distribution may be income-tax-free yet still required under the inherited-account schedule.

What is the penalty for missing an RMD?

Current Form 5329 instructions generally impose 25% of the shortfall, potentially reduced to 10% for timely correction within the statutory window. The IRS may waive the tax for reasonable error when reasonable corrective steps are taken and the prescribed waiver request is filed. For a decedent’s unpaid death-year RMD, the tax is waived automatically if the beneficiary takes it by the later of the beneficiary’s return due date, including extensions, for the death year or the end of the following year.

Can all retirement accounts be combined for one RMD?

No. Aggregation is limited. Traditional IRAs can often be aggregated within the permitted group, but qualified employer plans generally must satisfy their own RMDs. Inherited accounts require compatible ownership and decedent groupings.

Primary sources

• IRS Publication 590-B
• IRS RMD FAQs
• IRS beneficiary rules
• IRS IRA-beneficiary RMD chart
• Instructions for Form 5329
• Final RMD regulations, effective for 2025 distribution years

The defensible result is an account-level schedule showing whether a death-year RMD existed, what the owner took, what remains, who receives it, how it is reported, what the beneficiary must do next, and how any shortfall was corrected.

This guide provides general educational information, not individualized tax, legal, or investment advice. RMD results depend on account type, plan terms, dates of birth and death, required beginning date, beneficiaries, documentation, elections, and current law. Engage a qualified retirement-tax professional before distributing, rolling over, retitling, aggregating, or correcting an inherited account.