When do I take my first RMD from a pension lump sum rollover to an IRA?

[miltf]

Wouldn't these RMDs be on my 2019 tax return which I file next year?

[macuser_22]

Yes, the 1099-R for the rollover will be.  But since the 2018 RMD was missed and taken late, the 2018 5329 is required to request a waiver and explain to the IRS why it was taken late.

[miltf]

And then I pay the taxes on both the 2018 and 2019 RMDs with my 2019 return?

[dmertz]

Yes.

[miltf]

So, I already filed a 5329 with my 2018 return since I took a 2018 IRA RMD in 2019.  Can I file a second one specifically for the missed pension RMD?

[dmertz]

Requesting a waiver of the penalty is only necessary when the RMD is late.  In your case, no 2018 Form 5329 requesting a penalty waiver would have been necessary had you completed the RMD by April 1, 2019.  If you inadvertently already filed 2018 From 5329 Part IX requesting waiver of the excess accumulation penalty on the amount of your late (after April 1) 2018 RMD, there is no need to do so again.

[miltf]

The IRA RMD was completed by Apr 1, but Turbotax had me fill out the 5329 anyway.  I didn't expect to have to do that, but did what TT said.  The pension RMD (a different amount than the late IRA RMD) is actually late (Apr 5) so I presume a 5329 is necessary for that.  Does the IRS really know the actual date of the RMD or are they just told the RMD amount and the year of the withdrawal?

[dmertz]

The answers to TurboTax's question as to whether you completed all of your RMD don't properly accommodate taking the first RMD early the following year and tend to imply a waiver is required when it really isn't.  It appears that the Form 5329 and explanation that you filed is actually inaccurate, so it probably makes sense to correct it.

The IRS can only determine the date of a distribution by performing an audit where they require you to provide copies of account statements or transaction statements that your IRA or plan trustee has provided to you.  Requesting a waiver and the IRS not denying the waiver heads off the IRS later assessing an excess accumulation penalty (although the IRS doing so seems unlikely given their general lack of RMD enforcement to date).

[SweetieJean]

Did you have an IRA in 2018?  If so, since you turned age 70.5 in 2018, your first RMD was supposed to have been taken by April 1, 2019.  

[Critter]

Did you not take an RMD from the pension in 2018?

[miltf]

No, I didn't take an RMD from the pension in 2018.  I didn't get a distribution (lump sum) until 2019.

[miltf]

I did take RMDs from my IRAs and my 401(k) in 2018. And I will again in 2019.  I am asking specifically about the pension that was taken as a lump sum in 2019 and rolled into an IRA.

[fanfare]

If you took RMDs from your 401k and IRAs then you know what is involved (presumably). Just keep doing what you've been doing.

[macuser_22]

Are you saying that you were not receiving any pension payments prior to taking a lump sum?  Usually the choice is either a monthly pension or a lump sum.

[macuser_22]

In any event, the 2019 IRA RMD amount is based on the IRA value as of December 31, 2018, so anything that was not in the IRA at that time would not be part of the 2019 IRA RMD.  The RMD for the retirement account that was rolled into the IRA must have been satisfied and removed, prior to the rollover.