RBD Timing · IRS 2024 Final Regulations · June 2026
If the IRA owner died on or after their required beginning date (RBD), many beneficiaries do not get to simply wait until the end of year 10. Under IRS beneficiary rules, intermediate-year minimum distributions may apply for certain non-exception designated beneficiaries, while the account still generally must be fully distributed by the end of year 10 in many cases.
If the IRA owner died on or after their required beginning date (RBD), many beneficiaries do not get to simply wait until the end of year 10. Under IRS beneficiary rules, intermediate-year minimum distributions may apply for certain non-exception designated beneficiaries, while the account still generally must be fully distributed by the end of year 10 in many cases.
That is the part most people miss. The "10-year rule" is real, but it is not always a "do nothing until year 10" rule when the owner died on or after RBD.
The phrase "RMD age" is common shorthand, but the IRS uses the term required beginning date (RBD). That is the date by which the original IRA owner had to start taking their own required minimum distributions.
The safest way to think about it is: death date vs. RBD is the first fork in the road.
To figure out inherited IRA RMD timing, you usually need to answer two questions: Did the owner die before or after the RBD? and what type of beneficiary are you? Those two facts determine whether minimum distributions may be due during the 10-year period.
If the owner died on or after RBD, the IRS rules can require beneficiary distributions earlier than many people expect. In plain English: the inherited account may need to be drawn down over time, not parked untouched until year 10.
The IRS distinguishes between spouses, non-spouse designated beneficiaries, and eligible designated beneficiaries. Whether you must take distributions in intermediate years depends on whether you are an eligible designated beneficiary or a non-exception designated beneficiary under IRS rules.
| Scenario | Annual minimums during 10-year period? | Final year-10 deadline? |
|---|---|---|
| Non-EDB, owner died after RBD | Often yes — intermediate-year minimums may apply | Yes — still must be emptied by end of year 10 |
| Non-EDB, owner died before RBD | Often no annual minimum | Yes — must be emptied by end of year 10 |
| EDB | Different schedule may apply | Depends on category and IRS method |
For many beneficiaries, the inherited IRA still has to be fully depleted by the end of the 10th year after the owner's death. But when the owner died on or after RBD, the IRS rules can also require annual or intermediate-year minimum distributions during that 10-year window for certain beneficiaries, depending on beneficiary category.
That means the 10-year rule has two layers:
This is where a lot of confusion happens. People hear "10-year rule" and assume they can wait. For this specific scenario, that assumption can be costly.
If you wait too long and miss an annual minimum, the IRS may view that as an under-distribution for that year. The penalty is not based on the full account. It is based on the shortfall.
If an inherited IRA beneficiary takes less than the required amount for the year, the IRS can impose a 25% excise tax on the shortfall. The penalty applies to the amount by which the required amount exceeds the amount actually distributed, unless IRS waiver or relief procedures apply for the relevant year and facts.
| Item | Amount |
|---|---|
| Required distribution for the year | $8,000 |
| Beneficiary took out | $5,000 |
| Shortfall | $3,000 |
| Potential 25% excise tax | $750 |
That is why "close enough" is not good enough with inherited IRA RMDs.
The IRS has issued limited transition relief for certain missed-RMD situations, including relief referenced in Notice 2024-35 and in Publication 590-B. That relief depends on the year and the facts; it is not a permanent waiver and does not remove future required distributions.
The IRS issued final regulations on July 18, 2024, and those rules apply for determining RMDs for calendar years beginning on or after January 1, 2025. These final regulations update RMD computation and administrative mechanics for years beginning in 2025. The inherited IRA beneficiary framework still depends on the IRS timing distinctions, including whether the owner died before or after the RBD and what type of beneficiary you are.
A lot of explanations stop at "The SECURE Act created the 10-year rule." That's incomplete. The fuller IRS picture is:
The IRS uses Publication 590-B to explain inherited IRA RMD rules and the life expectancy factors used in certain calculations. If you are trying to confirm timing or compute a required amount, this is one of the first IRS documents to review.
One common mistake is assuming every inherited IRA uses the same table or same timing rule. The correct method depends on:
If you are unsure, verify the category first, then look at the calculation method in the inherited IRA beneficiary sections of Publication 590-B.
The SECURE Act made the inherited IRA landscape more restrictive for many beneficiaries by creating the modern 10-year rule. SECURE 2.0 affected the original owner's RMD start timing for some people, which can change whether death occurred before or after the RBD. But neither law removes the need to apply the death-timing rules correctly.
For inherited IRA beneficiaries, the most important question is still: Did the owner die before or after the RBD? That timing question can override the simplistic "just use the 10-year rule" summary you may see elsewhere.
The easiest way to approach inherited IRA RMD timing is to use a two-step workflow: first determine whether the owner died before or after RBD, then confirm the beneficiary category. Those two facts drive the distribution schedule.
Gather:
Ask whether the beneficiary is a spouse, a non-spouse designated beneficiary, or an eligible designated beneficiary.
Review the IRS beneficiary guidance and Publication 590-B to determine:
If the inherited account holds precious metals, the IRS distribution rules still apply. A gold IRA does not change the RMD requirement; it only changes the operational way the distribution may need to happen.
To satisfy an inherited IRA RMD, the beneficiary may need to:
Potential cost buckets may include, depending on provider:
Because these costs vary by provider, the right approach is to review the actual custodian fee schedule and any dealer pricing sheet before assuming a distribution will be simple or inexpensive.
Before a deadline approaches, ask the custodian:
The rules are often stricter than many beneficiaries expect. For many beneficiaries, the IRS rules can require minimum distributions during the 10-year period — not just emptying the account in year 10. Whether intermediate-year minimums apply depends on the beneficiary's category and the owner's death timing.
For many non-exception designated beneficiaries, yes — the IRS rules can require annual or intermediate-year minimum distributions during the 10-year window in addition to the final clean-out. This is the part most people miss when they hear '10-year rule.'
The IRS can impose a 25% excise tax on the shortfall. The penalty applies to the amount by which the required amount exceeds the amount actually distributed. It can be reduced to 10% if corrected within the IRS correction window, unless IRS waiver or relief procedures apply.
The IRS issued final regulations on July 18, 2024, and those rules apply for determining RMDs for calendar years beginning on or after January 1, 2025. These regulations update RMD computation and administrative mechanics. Inherited IRA beneficiaries should use the current IRS framework rather than relying on older summaries.
No. The IRS distribution rules still apply regardless of what the IRA holds. What changes is the operational side: metals may need to be liquidated before a cash distribution can be made. Custodian processing fees, liquidation timing, and dealer pricing are all relevant to whether you can meet the deadline on time.