What changed and the fork
The SECURE Act (2019) killed the classic "stretch IRA" for most non-spouse beneficiaries of deaths in 2020 or later. The replacement is the 10-year rule: the inherited account must be fully distributed by December 31 of the 10th calendar year after the year of death. What the IRS spent four years fighting about was whether annual RMDs were also required during those 10 years. TD 10001 (July 2024) locked in the answer — and it depends on when the original owner died relative to their Required Beginning Date (RBD).
| Scenario | Owner died BEFORE their RBD | Owner died ON or AFTER their RBD |
|---|---|---|
| Annual RMDs in years 1–9? | No | Yes — required |
| Year-10 deadline? | Empty by Dec 31 of year 10 | Empty by Dec 31 of year 10 |
| Roth IRA | Roth owners are ALWAYS treated as dying before RBD (no lifetime RMDs). Distributions are generally tax-free — optimal move is usually to leave it growing until year 10. | |
RBD = April 1 of the year after the owner reached their applicable age: 70½ if born before July 1, 1949; 72 if born July 1, 1949 – December 31, 1950; 73 if born 1951–1959 (1959 under proposed regulations); 75 if born 1960 or later.
The 2021–2024 waiver — and why 2025 was the turning point
Between 2020 and 2024 the IRS kept issuing proposed regulations, then walking them back. In Notices 2022-53, 2023-54, and 2024-35 the agency waived the missed-RMD excise tax for beneficiaries who didn't take annual distributions in 2021–2024. TD 10001 — finalized in July 2024 — made clear that enforcement would begin with the 2025 distribution year. If you're a non-eligible designated beneficiary of an owner who died on or after their RBD, your first annual RMD year is the year after death. If the owner died in 2024 or earlier, 2025 was your first enforced RMD year and 2026 is your second. If the owner died in 2025, 2026 is your first annual RMD year; if in 2026, your first is 2027. There is no further waiver.
The subtract-one RMD math (worked example)
For fork (a) — died on/after RBD — the mechanics are:
- In the FIRST distribution year (the year after death), look up the beneficiary's Single Life Table factor for their age that year from IRS Pub 590-B. (The rule is the longer of your life expectancy and the owner's remaining life expectancy; a non-eligible beneficiary is more than 10 years younger, so yours is always the longer one.)
- Each subsequent year, subtract 1 from the initial factor — do NOT re-look-up the table. This is the "subtract one" method.
- Required RMD = prior Dec-31 balance ÷ that year's factor.
- In year 10, the entire remaining balance must come out.
Example. $500,000 inherited traditional IRA, beneficiary age 50 in the first distribution year, owner died after RBD. Age-50 single-life factor = 36.2.
- Year 1 required RMD = $500,000 ÷ 36.2 = $13,812.15.
- Year 2 factor = 35.2 (subtract one, not "age 51 table").
- Year 3 factor = 34.2, and so on.
- Year 10: the entire remaining balance must be distributed.
Missed a year? 25% (or 10%) excise tax
SECURE 2.0 §302 cut the missed-RMD penalty from 50% to 25%, and further to 10% if you correct the shortfall within the "correction window" (generally the earlier of the mailing of a deficiency notice, assessment of the excise tax, or the end of the 2nd year after the missed year). File Form 5329 to report it. If the shortfall was a reasonable error you are fixing, you can ask the IRS to waive the tax by attaching an explanation — the waiver is not automatic.
Who is NOT under the 10-year rule (EDBs and spouses)
Eligible designated beneficiaries (EDBs) may take distributions over a life expectancy instead of following the 10-year rule:
- Surviving spouse
- Minor child of the owner (until age 21, then the 10-year rule kicks in)
- Disabled or chronically ill individual
- Any beneficiary not more than 10 years younger than the owner
Generally that is their own life expectancy. If the owner died on or after their RBD and the owner's remaining life expectancy is longer (typically when the beneficiary is older than the owner), the owner's is used.
Spouses have extra options. A surviving spouse who is the sole beneficiary can treat the IRA as their own — rolling it into their own account, starting RMDs at their own applicable age (73 if born 1951–1959, 75 if born 1960 or later), and naming new beneficiaries. That is usually best from age 59½. If you are younger and may need withdrawals, keeping it as an inherited IRA avoids the 10% additional tax on early distributions, because distributions to a beneficiary after the owner's death are exempt. At 50, for example, a $10,000 withdrawal costs $1,000 in additional tax once the IRA is your own (unless another exception applies) and $0 as a beneficiary. You can generally make the own-IRA election later (it is limited once you reach RMD age). A trust named as beneficiary can't make this election.
Roth inherited IRAs
Roth owners never had lifetime RMDs, so under the regulations they're always treated as dying before their RBD. Non-eligible designated beneficiaries have no annual RMDs on an inherited Roth — just the 10-year deadline. Because qualified Roth distributions are generally tax-free, the standard advice is to leave the account invested and take a lump sum in year 10.
Pre-2020 deaths (out of scope)
If the original owner died in 2019 or earlier, you are governed by the old stretch rules — annual life-expectancy RMDs, no 10-year deadline. This guide and the linked calculator do not model pre-2020 stretch schedules.
Strategy: bracket-smoothing vs the year-10 spike
The single biggest planning lever is when you take the money out — not whether. Because the account MUST be empty by year 10, "minimum-only" withdrawals guarantee a huge distribution in year 10 that often lifts you into a higher marginal bracket for one year. Two smoothing strategies:
- Even-spread: distribute current balance ÷ years remaining each year. Kills the year-10 spike at the cost of accelerating tax slightly.
- Fill your bracket: pull extra dollars in years where you have "bracket room" (a low-income year, before Social Security starts, between jobs). Coordinate with your own Roth-conversion window — see the Roth Conversion 2026 guide for how to size both together.
- Lump-year-10: only legal when no annual RMDs are required (fork b or Roth). Maximizes tax-deferred growth, but you pay the whole tax bill in one year.
Frequently asked questions
Do I have to take an RMD from my inherited IRA in 2026?
It depends on the fork. If the original owner died ON OR AFTER their Required Beginning Date (RBD: April 1 of the year after the owner reached 70½, 72, 73 or 75, depending on birth date), then yes — non-eligible designated beneficiaries owe annual RMDs in years 1–9, starting the year after death, and must empty the account by year 10. If the owner died BEFORE their RBD (or the account is a Roth), there are no annual RMDs — only the year-10 deadline.
When must the inherited IRA be completely emptied?
By December 31 of the 10th calendar year after the year of death.
What if I missed RMDs in 2021–2024?
The IRS waived the missed-RMD excise tax for those years (Notice 2022-53, 2023-54, and 2024-35) while the final regulations were still being written. Enforcement began with the 2025 distribution year under TD 10001.
Is the 10-year rule different for a Roth?
Yes — Roth IRA owners never had lifetime RMDs, so the beneficiary is always treated as if the owner died BEFORE their RBD. That means no annual RMDs, only the year-10 deadline. Because qualified Roth distributions are generally tax-free, most beneficiaries let the account grow and take a lump sum in year 10.
What's the penalty for missing a year?
25% excise tax on the shortfall, reduced to 10% if you correct it promptly under SECURE 2.0 §302. Report on Form 5329.
This guide summarizes TD 10001 and IRS Pub 590-B. Beneficiary rules interact with estate documents, marital status, and prior elections — talk to a qualified professional before locking in a distribution strategy.