When an IRA owner who was already taking required minimum distributions dies partway through the year, the RMD does not die with them. It remains due for that calendar year, and the obligation shifts to the beneficiary.
IRS Publication 590-B states the rule for the most common case — a surviving spouse who takes over the account: "If you become the owner in the year your deceased spouse died, don't determine the required minimum distribution for that year using your life expectancy; rather, you must take the deceased owner's required minimum distribution for that year (to the extent it wasn't already distributed to the owner before their death)."
This is the quietest deadline in retirement tax law, and for 2025 deaths it runs out in roughly twelve weeks.
The Automatic Waiver, and What It Actually Waives
Final regulations issued in July 2024 created relief that applies to RMDs beginning on or after January 1, 2025. Under 26 CFR § 54.4974-1(g)(3), the excise tax is automatically waived — no Form 5329 request, no reasonable-cause letter — if the beneficiary "takes a corrective distribution in the amount needed to satisfy that distribution requirement no later than the tax filing deadline (including extensions thereof) for the taxable year of that beneficiary that begins with or within that calendar year (or, if later, the last day of the calendar year following that calendar year)."
Read the "later of" carefully. For a calendar-year beneficiary of an owner who died in 2025, the two candidate dates are April 15, 2026 and December 31, 2026. The later one governs: December 31, 2026. For a 2026 death, the date is December 31, 2027.
The precision matters because this is a waiver of a penalty, not an extension of a deadline. The RMD itself was legally due by December 31 of the year of death. The regulation forgives the consequence, not the lateness — and it forgives it only if the money comes out in time.
What is at stake is the excise tax under § 54.4974-1(a)(1): "25 percent of the amount by which the required minimum distribution for a calendar year exceeds the actual amount distributed during the calendar year," reduced to 10% if corrected within the correction window. On a $40,000 unsatisfied RMD, that is $10,000.
Three Details That Catch Families
Any one beneficiary can satisfy it. The 2024 final regulations confirmed that a single IRA's year-of-death RMD may be satisfied by one or more beneficiaries at their discretion. Proportional sharing is no longer presumed, which lets families route the taxable income to whoever is in the lowest bracket.
Aggregation reverses that flexibility. If the decedent was aggregating RMDs across multiple IRAs, the shortfall becomes the collective responsibility of the beneficiaries of all those accounts, apportioned pro rata by each IRA's fair market value. A beneficiary can therefore owe a share of a shortfall sitting in an account they never inherited and may not know exists.
The RMD cannot be rolled over. Publication 590-B is unambiguous: "Amounts that must be distributed (required minimum distributions) during a particular year aren't eligible for rollover treatment." A surviving spouse who moves the entire balance into their own IRA before extracting the year-of-death RMD has not deferred anything — they have created an excess contribution on top of an unsatisfied RMD.
Practical Takeaways
- Ask one question about every 2025 death: was the owner 73 or older? If yes, confirm in writing whether the full 2025 RMD was distributed before death.
- Request the decedent's distribution history, not just the year-end balance. The shortfall is the difference, and only the custodian's records show it.
- Hunt for other IRAs before assuming your share. Aggregation makes the decedent's full account map relevant to your liability.
- Take the year-of-death RMD before any spousal rollover or trustee-to-trustee transfer. Sequence is not optional here.
- Expect the income on your own return. The corrective distribution is reported on the beneficiary's Form 1040, not the estate's income tax return — so it lands in your bracket, in the year you take it.
- Do not wait for a notice. The waiver is automatic, but it is conditional. Nothing arrives in the mail to tell you the clock is running.
A missed year-of-death RMD is one of the few retirement tax errors with a free, no-paperwork cure. It is also one of the easiest to discover a year too late.
Sources: 26 CFR § 54.4974-1 – Excise tax on accumulations in qualified retirement plans; IRS Publication 590-B – Distributions from Individual Retirement Arrangements (IRAs); IRS – Retirement Plan and IRA Required Minimum Distributions FAQs; Ascensus – RMD Regulations' Year-of-Death Rules Yield Both Answers and Questions; Phillips Lytle – New IRS Regulations on Year-of-Death RMDs