rbynaker
Level 14

It sounds like someone is confusing a corrective distribution of an excess contribution with a missed RMD.

The 2024 RMD is calculated based on the FMV of the account on 12/31/23.

The missed 2023 RMD is reported on the 2023 Form 5329 Part IX with a waiver request for "reasonable cause" and $0 penalty (something perhaps more polite than "trustee action resulted in an ID10T error".)  All of my RC waiver requests include a statement that the missed RMD has been taken and procedures have been put in place to prevent the error for happening again.

I suspect the IRS may start pushing back on RC waivers now that the penalty is lower but I haven't seen that in practice yet.  Time will tell, until then I plan to continue requesting reasonable cause waivers.

Rick

Added: I started this then got a call from a client and see that Anna also chimed in with a similar response.