Transition relief provided for change in RMD beginning date

July 20, 2023

The IRS provided transition relief regarding the change in the required beginning date for required minimum distributions (RMDs) under the SECURE 2.0 Act in the recently issued Notice 2023-54.

The SECURE 2.0 Act changed the required beginning date for RMDs under Sec. 401(a)(9). Originally, the defined required beginning date referred to April 1 of the calendar year following the calendar year in which someone reaches age 72.

The new required beginning date is defined by reference to April 1 of the calendar year after the calendar year in which someone reaches the applicable age of 73 or 75, depending on the date of birth.

Plan administrators and other payers of RMDs expressed concern that updates to automated payments systems needed to reflect the change in the required beginning date could take some time to implement.

In response, the IRS is granting certain relief relating to certain distributions made during 2023 to individuals characterized as RMDs but are not actually RMDs because of the SECURE 2.0 Act.

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