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Section 4974 Excise Tax · IRS Rules · June 2026

Inherited IRA RMD Penalty: What Happens If You Miss an RMD, and When the 25% Excise Tax Can Drop to 10%

By The Retirement Index Editorial Team

Published Last reviewed Fact-checkedCites IRS, SEC, FINRA, CFPB

By The Retirement Index Editorial Team · · Next review: · Affiliate disclosure

Quick answer

If you were required to take an RMD from an inherited IRA and took less than required, the IRS can charge an excise tax on the shortfall. For taxable years beginning after December 29, 2022, that penalty is generally 25% of the missed amount, and it can drop to 10% if you correct it within the IRS correction window. The excise tax is reported on Form 5329.

What people mean by the "inherited IRA RMD penalty"

Most people use "inherited IRA RMD penalty" to describe the IRS excise tax for missing a required minimum distribution from an inherited IRA. This is not the same thing as the 10% early-withdrawal tax that applies in other retirement-account situations. If the IRS treats your situation as an RMD failure that generates a Section 4974 excise tax on excess accumulation, the additional tax is reported on Form 5329 as directed by its instructions.

Excise tax vs. other retirement taxes

It helps to separate three different tax ideas:

  1. RMD excise tax — the penalty for missing a required distribution
  2. 10% early distribution tax — a different penalty that can apply to certain retirement withdrawals before age 59½
  3. Ordinary income tax — may still apply to the distribution itself, depending on the account and your tax situation

Do inherited IRAs always have RMDs?

An inherited IRA does not always create the same RMD rules for every beneficiary. Whether you owe an RMD depends on facts like:

  • Whether you are the spouse or a non-spouse beneficiary
  • Whether the original account owner died before or on/after their required beginning date (RBD)
  • Which inherited IRA distribution framework applies to your situation

Depending on your beneficiary classification and the decedent's death timing, you may not have an annual RMD requirement, but you generally still must satisfy required distributions under the applicable inherited IRA framework by specific deadlines.

Quick fact-pattern checklist

Before worrying about a penalty, check these four items:

  1. Who are you? Spouse, non-spouse, trust, or estate beneficiary
  2. When did the account owner die? Before or on/after their RBD
  3. What rule applies? A 10-year rule framework or annual RMD framework
  4. Did you miss a distribution year? If yes, what amount was required?

How the 25% penalty is calculated

If you were required to take an RMD and took less than required, the IRS calculates the penalty on the shortfall:

Shortfall = Required RMD − Amount actually distributed

Excise tax = Penalty rate × Shortfall

Simple example (illustrative only)

ItemAmount
Required inherited IRA RMD$20,000
Amount actually withdrawn$12,000
Shortfall$8,000
25% excise tax$2,000
10% rate if corrected in time$800

That is why the timing of the correction matters so much.

What is the IRS correction window?

The IRS correction window is the period during which a missed RMD can be corrected and the excise tax reduced from 25% to 10%. The IRS generally describes it as ending at the end of the second calendar year following the first year beginning after the year in which the failure occurred.

IRB 2024-19 explains the IRS correction-window concept that can reduce the Section 4974 excise tax, which is reported on Form 5329.

The correction window is about when the missed amount is fixed, not whether the mistake was accidental. The reduced rate is not automatic. You need the correction to happen inside the IRS timing rule.

Is there an inherited IRA RMD penalty waiver?

There is no blanket inherited IRA RMD penalty waiver that wipes out the penalty for everyone. The IRS has provided targeted relief in certain situations, but that relief is narrow and fact-specific.

For example, the IRS beneficiary guidance references relief under Notice 2022-53 for certain beneficiaries subject to the 10-year rule who failed to take RMDs for 2021 and 2022. That is not the same thing as a general waiver for all missed inherited IRA RMDs in every year.

What that means in practice

If you see online claims about a "waiver," treat them carefully. You still need to check:

  • The year the RMD was missed
  • Your beneficiary category
  • Whether the IRS relief you found actually matches your facts

How to report the penalty

If the IRS treats your situation as an RMD failure that generates a Section 4974 excise tax on excess accumulation, the additional tax is reported on IRS Form 5329 as directed by the IRS instructions. The form instructions explain the penalty rate and how the reduced rate can apply if you meet the correction rules.

Basic Form 5329 workflow

  1. Confirm whether you had an RMD obligation
  2. Calculate the required amount and the amount actually distributed
  3. Figure out the shortfall
  4. Check whether you corrected it within the IRS correction window
  5. Use Form 5329 if the excise tax is due

Common mistakes that trigger the inherited IRA RMD penalty

  • Assuming every inherited IRA has the same RMD rule
  • Mixing up the 10-year rule with annual RMD requirements
  • Forgetting the role of the original owner's required beginning date
  • Taking part of the RMD but not enough
  • Taking the right amount too late
  • Assuming the custodian's process overrides IRS rules
  • Believing there is a general waiver when there usually is not

The IRS cares about the correct amount, the correct year, and the correct timing.

Gold IRA context: do the rules change?

The tax rule does not change just because the inherited IRA holds gold instead of mutual funds or cash. The IRS distribution requirement is based on the IRA rules, not the asset mix inside the account.

What can change is the operational side:

  • Gold may need to be sold to create cash for the RMD
  • Custodian processing time can matter
  • Dealer pricing and spreads can affect how quickly you can raise the needed amount
  • Distribution timing can become tight near year-end

Operational timing can still affect whether you meet the distribution deadline, which affects excise-tax exposure if an RMD was required.

What to do if you already missed an inherited IRA RMD

If you think you missed an inherited IRA RMD, do not guess. Work through this order:

  1. Confirm whether an RMD was actually required for that year
  2. Calculate the shortfall
  3. Check whether you are still inside the IRS correction window
  4. Gather your custodian records and tax documents
  5. Use Form 5329 if needed
  6. Ask a qualified tax professional about the filing and correction steps

The goal is to fix the problem correctly and as soon as possible, because the difference between a 25% and 10% excise tax can be large.

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Scenario guide: who is most likely to owe an inherited IRA RMD?

Spouse beneficiary

A surviving spouse may have different inherited IRA options than a non-spouse beneficiary. The RMD result depends on the path chosen and the facts of the account.

Non-spouse beneficiary

Non-spouse beneficiaries are often subject to a distribution framework that can include the 10-year rule, but the exact RMD obligation depends on the IRS rules that apply to the account owner's death date and the beneficiary category.

Trust or estate beneficiary

These situations can be more complex, and the distribution rules may depend on how the account was titled and who the IRS treats as the beneficiary.

Death before vs. after RBD

The owner's death relative to their required beginning date can change the distribution framework. That timing detail matters before you ever get to the penalty question.

FAQ: inherited IRA RMD penalty

Is the inherited IRA RMD penalty always 25%?

Generally, for taxable years beginning after December 29, 2022, the excise tax is 25% of the shortfall. If you correct the missed RMD within the IRS correction window, it may be reduced to 10%.

What is 'excess accumulation' in the context of inherited IRA RMDs?

It is the amount that should have been distributed but was not — the shortfall the IRS uses to calculate the excise tax. The IRS Form 5329 instructions use the term 'excess accumulation' for this missed amount.

Can I avoid the inherited IRA RMD penalty by taking the distribution late?

Sometimes the penalty can be reduced if you correct within the IRS correction window, but taking it late does not automatically erase the tax. You still need to file Form 5329 and address the excise tax reporting.

Is there a general waiver for missed inherited IRA RMDs?

No. The IRS has provided targeted relief in some specific situations (such as Notice 2022-53 for 2021–2022 misses), but there is not a blanket waiver for everyone.

Is the inherited IRA RMD penalty the same as the 10% early withdrawal tax?

No. The inherited IRA RMD penalty is a Section 4974 excise tax on 'excess accumulation' — the amount not distributed. It is separate from the 10% early distribution tax that applies to premature withdrawals from retirement accounts.