June 7, 2019 3:06 PM
Yes, the Form 5329 requesting the waiver must be filed with your 2015 tax return. This distribution will be reported on your 2016 tax return. Keep in mind, if the IRS wants to impose the 50% excess accumulation penalty, you are the one who will receive the deficiency notice since the responsibility to complete the RMD became yours as beneficiary.
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