In February of 2022, the IRS released guidance that called for beneficiaries—under certain circumstances—to take annual required minimum distributions while also being subject to the new 10-Year Rule.
The IRS released Notice 2022-53 which provided an exemption from the excess accumulation penalty related to annual required minimum distributions for:
- beneficiaries who are subject to the 10-Year Rule in scenarios when the IRA owners and plan participants passed away on/after their required beginning date in 2020 or 2021, and
- successor beneficiaries who are required to take annual distributions in addition to depleting the account within 10 years following the death of an Eligible Designated Beneficiary.
The relief is explicitly limited to beneficiary-required distributions for calendar years 2021 and 2022.