unfortunately, the 5329 goes with the tax year you missed,
and the late distribution goes with the tax year you took the distribution.
Note: the IRS rule is still a proposed rule.
Notel The IRS always grants a waiver of the 50% penalty when you ask for a waiver and take timely action.
You could argue that you don't need to take a 2021 RMD because the ruling still has not been finalized, and did not exist at all in 2021.
@bmwermuth
@dmertz
