Thanks for your response. So you recommend using forms available from the IRS rather than trying to use each year's version of TurboTax and filing through the system.

jtax

Level 10

Good question.

The Form 5329 instructions tell you that you cannot file (or efile) an amended return unless something other than the 5329 has changed. You could certainly use forms mode in TT desktop for the years in question and print out and mail the forms per the instructions. You must use the Form 5329 for the correct year. Sometimes the forms are changed. Prior year forms will be in that year's TT or at https://www.irs.gov/prior-year-forms-and-instructions?find=form5329

https://www.irs.gov/instructions/i5329#en_US_2025_publink13330rd0e160

If you don’t have to file a 2025 income tax return, complete and file Form 5329 by itself at the time and place you would be required to file Form 1040, 1040-SR, or 1040-NR. If you file Form 5329 by itself, then it can’t be filed electronically. Be sure to include your address on page 1 of the form and your signature and the date on page 3 of the form. For payment options see the Instructions for Form 1040 or the Instructions for Form 1040-NR, or go to IRS.gov/Payments to see all your payment options.

Prior tax years.

If you are filing Form 5329 for a prior year, you must use the prior year's version of the form. If you don’t have any other changes and haven’t previously filed a federal income tax return for the prior year, file the prior year's version of Form 5329 by itself (discussed earlier). If you have other changes, file Form 5329 for the prior year with Form 1040-X, Amended U.S. Individual Income Tax Return.

I suppose the "and haven't previously filed" makes the instructions technically ambiguous. What if you don't have any other changes and have previously filed a return. Hmm. You could enter the info in the older TT desktops and see if it lets you efile a 1040X. If not, print and mail just the 5329. Otherwise, you could try efiling.

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Opus 17

Level 15

Hold on there a second.

Even though inherited IRAs are subject to RMDs beginning in 2021, (due to the SECURE Act, I think) the IRS has waived all penalties for missing the RMD for tax years 2021-2024 because the regulations, forms and instructions were not ready.

https://www.forbes.com/sites/davidrae/2024/04/28/irs-waives-2024-rmds-for-inherited-ira-beneficiaries/

You have nothing to correct. As long as you withdrew your 2025 RMD on time, you are good to go. You still have the 10 year close-out rule to deal with and RMDs until then.

SemantaxAuthor

Level 2

Thank you for your response. I checked with ChatGPT about whether a 5329 needs to be filed and received this response. As my Inherited IRA is for a RBD it appears I should still file the 5329, and don't think there is a downside but welcome your further thoughts:

Where the forum answer overstates things

“You have nothing to correct.”

That is not universally true.

The IRS waived penalties, not reporting requirements.

The key question (this determines the answer)

Did the original IRA owner die after their Required Beginning Date (RBD)?

If YES → Annual RMDs were legally required in 2021–2024
If NO → No annual RMDs were required during the 10-year period

This distinction is critical.

Opus 17

Level 15

I disagree with ChatGPT. Please review IRS notice 2024-35.

https://www.irs.gov/pub/irs-drop/n-24-35.pdf

If there is no penalty, there is no reporting requirement. Or, if you want to nitpick, if there is no penalty, then any report you file is meaningless.

If you want to file 4 years worth of form 5329, reporting an RMD not taken, calculating a penalty, and asking for a waiver on the basis of notice 2024-35, I can't stop you. But it would be wasted effort.