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Heirs whose parent had already started withdrawals must now take a yearly distribution too

Families who inherited an IRA from a parent who had already begun taking required minimum distributions now face an obligation many did not expect: they must withdraw a calculated amount every year, on top of emptying the account within a decade. The IRS finalized the rule on July 19, 2024, ending years of confusion over whether annual distributions applied during the 10-year window created by the SECURE Act. For non-spouse beneficiaries, the practical result is a forced acceleration of taxable income that reshapes retirement planning for thousands of households.

Annual withdrawal mandate for post-RBD inherited IRAs

The distinction turns on a single question: had the original account owner already reached what the IRS calls the “required beginning date” before dying? If so, the heir cannot simply let the inherited IRA sit untouched until the end of the tenth year. Instead, the beneficiary must take distributions each year, calculated using life expectancy tables in IRS Publication 590-B, and then drain whatever remains by December 31 of the tenth calendar year after the owner’s death.

The IRS spelled out this interpretation in Internal Revenue Bulletin 2022-45, which states that where the employee or IRA owner dies after the required beginning date and the beneficiary is a non-eligible designated beneficiary subject to the 10-year rule, annual RMDs must continue after death and the account must be fully distributed by the end of the tenth year. That language drew immediate attention because many heirs and their advisors had assumed the 10-year clock was the only constraint, with no yearly floor on withdrawals.

How the July 2024 final rule locked in the requirement

After proposing the annual-distribution framework in 2022, the Treasury Department and IRS took two years to finalize it. The Government Accountability Office confirmed the completed regulation, identified by RIN 1545-BP82, as a major rule published in the Federal Register on July 19, 2024. That designation signals an expected economic impact of at least $100 million annually, a threshold that itself hints at the revenue the government anticipates collecting from these accelerated distributions.

During the gap between the proposed and final rules, the IRS offered transition relief, waiving penalties for beneficiaries who missed annual withdrawals in certain years. The agency’s RMD FAQ page reflects the updated age thresholds and explains how the 10-year rule interacts with annual distribution obligations. With the final regulation now in place, that grace period has effectively closed for future tax years, and beneficiaries who skip a required withdrawal risk a steep excise tax on the shortfall.

Tax consequences splitting two groups of heirs apart

The rule creates a clear divide among non-spouse beneficiaries. Those who inherited from an owner who died before the required beginning date still operate under a simpler version of the 10-year rule: empty the account by the deadline, but choose their own pace along the way. Those on the other side of the line, inheriting from someone who had already started RMDs, must now layer annual withdrawals on top of the 10-year deadline.

In practice, that means two siblings can face very different tax trajectories depending on when a parent died relative to the required beginning date. One might be free to defer withdrawals until a year with lower income, while the other is forced to recognize taxable income every year, even if it pushes them into a higher bracket. The rule also interacts awkwardly with other tax-sensitive events, such as exercising stock options or selling a business, because inherited IRA income can no longer be bunched entirely into a single low-income year.

Advisors note that the new framework may encourage more strategic use of Roth conversions and charitable bequests during the original owner’s lifetime. By shifting some funds into Roth accounts, which follow different distribution rules, or leaving tax-deferred assets directly to charity, families can reduce the future burden on non-spouse heirs who would otherwise be trapped by the combined annual-and-10-year requirement.

Compliance, penalties, and where to get help

For beneficiaries trying to navigate the rules, accurate information about their status as designated or non-eligible designated beneficiaries is crucial. The IRS encourages taxpayers to use its online account tools to review prior filings, monitor payments, and confirm how distributions have been reported; these services are available through the agency’s online account portal. Keeping records synchronized with IRS data reduces the risk of mismatched 1099-R forms and unexpected notices.

Those who discover they have missed a required distribution may still have options to request penalty relief. While the final rule curtails broad transition waivers going forward, the existing framework for reasonable-cause relief remains in place, and taxpayers can work with professionals to document errors and corrective steps. The IRS maintains a separate gateway for taxpayers who need help managing installment plans or other obligations, accessible through its online payment system.

Given the complexity of inherited IRA rules, many families will benefit from working with enrolled agents, CPAs, or tax attorneys who regularly handle retirement distributions. Practitioners can access specialized e-services and guidance through the IRS’s dedicated tax professional portal, which supports secure messaging and transcript delivery. Coordinating advice among tax, financial planning, and estate professionals can help heirs design a withdrawal schedule that satisfies the annual mandate, meets the 10-year deadline, and minimizes avoidable tax shocks.

For now, the message from regulators is clear: the era of “wait until year ten” for many inherited IRAs is over. Beneficiaries who inherited from someone already past the required beginning date must build annual distributions into their financial plans, or risk penalties that can quickly erode the value of their legacy.

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Daniel Harper

Daniel is a finance writer covering personal finance topics including budgeting, credit, and beginner investing. He began his career contributing to his Substack, where he covered consumer finance trends and practical money topics for everyday readers. Since then, he has written for a range of personal finance blogs and fintech platforms, focusing on clear, straightforward content that helps readers make more informed financial decisions.​


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