The Internal Revenue Service (“IRS”) issued Notice 2023-54 (“Notice”) that provides relief from Code Sec. 401(a)(9) required minimum distribution (“RMD”) compliance for certain 2023 lifetime and post-death distributions to participants and beneficiaries under individual retirement accounts (“IRAs”) and employer plans. The guidance largely tracks similar guidance that was previously under Notice 2020-51 and Notice 2022-53. In short—

  • the pending RMD regulations (for all plan types) will not be effective before the 2024 distribution calendar year;
  • relief for errors with respect to the Setting Every Community Up for Retirement Enhancement (“SECURE”) 2.0 “required beginning date” change, including (1) extending the 60-day indirect rollover period through September 30, 2023, (2) relief from the one-per-12-month IRA indirect rollover limitation, and (3) plan sponsor relief for noncompliance with Code Secs. 401(a)(31), 402(f), and 3405(c) withholding; and
  • no 2023 RMD payments need to be made for beneficiaries receiving “specified RMD” payments (“at least as rapidly” rule relief).

In this TAXES – The Tax Magazine article, Groom principals Elizabeth Dold and David Levine explore the Internal Revenue Service’s (“IRS”) notice on RMD requirements and the potential effects on qualified plans and IRAs.

To read the article, click here.


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