IRS Releases Guidance and Transition Relief Relating to Certain RMDs

Published July 17, 2023

The Internal Revenue Service (IRS) issued Notice 2023-54 providing transition relief for plan administrators, payors, plan participants, IRA owners, and beneficiaries in connection with the change in the required beginning date for required minimum distributions (RMDs) under § 401(a)(9) of the Internal Revenue Code (IRC) pursuant to § 107 of the SECURE 2.0 Act of 2022 (SECURE 2.0 Act). 

Section 107 of the SECURE 2.0 Act amended § 401(a)(9) of IRC to change the required beginning date applicable to § 401(a) plans and other eligible retirement plans, including IRAs. Rather than defining the required beginning date by reference to April 1 of the calendar year following the calendar year in which an individual attains age 72, the new required beginning date for an employee or IRA owner is defined by reference to April 1 of the calendar year after the calendar year in which the individual attains the applicable age (which is either age 73 or age 75, depending on the individual’s date of birth).

The notice also:
  • Provides guidance related to certain specified RMDs for 2023, including:
    • Guidance for defined contribution plans that did not make a specified RMD;
    • Guidance for certain taxpayers who did not take a specified RMD; and
    • Definition of specified RMD.
  • Announces that the final regulations that the Department of the Treasury and IRS intend to issue related to RMDs will apply for purposes of determining RMDs for calendar years beginning no earlier than 2024.