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After you file
You must file 2012, 2013, 2014, 2015 2016 and 2017 Forms 5329 requesting waiver of the 50% excess accumulation penalties for those years. You can send these together in a single envelope, but they must be sent separately from your 2018 tax return.
Your 2018 tax return will not include Form 5329 unless there is some other reason it is needed. You aren't requesting a waiver for 2018 because you took the 2018 RMD timely.
‎June 4, 2019
8:17 PM