I took an RMD in December 2024, money deposited on January 3rd 2025 but never received a 1099R. How do I prove that I did take the RMD when I never received the paperwork?

[Katie-P]

If this was not your first year where you were required to take a Required Minimum Distribution (RMD), you would have needed to take the RMD by December 31st. Even though you initiated the process prior to that time, you were not in constructive receipt of the RMD until January. This means that you did not actually take your RMD for 2024.

Your situation requires you to file Form 5329. If you are using TurboTax Desktop, follow these steps:

You will enter it on Form 5329, Box A is the "Waiver of Tax Smart Worksheet" under line 53 in the TurboTax Desktop form mode.

1. Enter the forms mode and click on "Open Form" and type "5329".
2. Scroll down to Part IX line 52 and enter the RMD amount that should have been taken. On line 53 enter the amount of the RMD that was actually taken (probably zero if it was missed).
3. Then in the box right (labeled A) under line 53 "Waiver of Tax Smart Worksheet" enter the same amount as line 52 (the RMD amount).
4. Click the "Explanation" button and enter the reason for missing the RMD and your statement requesting a waiver.

If using the TurboTax Online version and have no 2024 Form 1099-R to file, you will have to prepare the 5329 manually.

Download Form 5329 from the IRS website and fill it out the same as above. Print and mail your return with the 5329 form and explanation attached as described in the 5329 instructions. The 2024 Form 5329 must be attached to your printed and mailed 2024 tax return and cannot be e-filed.

Please be aware that you can only use this method if you are requesting a waiver of the penalty and there is no taxable amount on Form 5329 form line 55 that must be transferred to Schedule 2 line 8.

[user17579891076]

Hi Katie P. -

Thank you for the response! Sorry this is late....  I'm a bit confused and just need some clarification on your response. I turned 73 in 2024 so would have had until April 1st 2025 to take my first RMD. Therefore, the money I received on January 3rd 2025 should qualify for that RMD - correct? If so, do I still complete Part IX lines 52 and 53 on form 5329? I believe I do but wondered because I technically did not miss my first RMD on that IRA. I don't know if it makes a difference but this was a small IRA from a previous employers payroll company and I took a full distribution to close it out

Also, I have another IRA that I took the first RMD, was paid on 12/29/24 and received my 1099R by mid January. That 1099R has been entered into TurboTax. Do I need to also show that RMD information on lines 52 & 53 of Form 5329?

Thank you so much for your help!

[Katie-P · Accepted solution]

Hi @user17579891076,

With this additional context that you turned 73 in 2024, you are correct that you would have had until April 1, 2025 to take the RMD from your IRA. In this case, you do not need to fill out form 5329 for tax year 2024. 

For the IRA distribution that you received on 12/29/24, for which you have a 2024 1099-R, you would enter that in the TurboTax interview, and when you reach the area that asks for the RMD due by 12/31/24, you would enter a 0, because your RMD was not due until April 1, 2025, since you just turned 73 in 2024. 

Again, there will be no need for a form 5329 for you for tax year 2024, given that you had no RMD due until April 1, 2025.