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Anonymous
Not applicable

Was 70 1/2 last year - missed the 4/1/17 RMD deadline by 4 days - distribution taken 4/4/17. Do I complete a form 5329 for 2016 or 2017?

 
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dmertz
Level 15

Was 70 1/2 last year - missed the 4/1/17 RMD deadline by 4 days - distribution taken 4/4/17. Do I complete a form 5329 for 2016 or 2017?

2017 Form 5329.

That it should be reported on the 2017 Form 5329 and not the 2016 Form 5329 is not at all apparent.  It comes down to one statement in the instructions for Form 5329, "The tax is due for the tax year that includes the last day by which the minimum required distribution must be taken."  Since the last day in this case was April 1, 2017, it means that the tax would be due for 2017 and that the missed distribution would be reported on a 2017 Form 5329.  Of course you'll request a waiver of the penalty on that form based on now having made the late distribution.  You'll include this with your 2017 tax return.

Lines 52 and 53 of the 2017 Form 5329 will include your 2017 RMD required to be taken by the end of this year.  Lines 54 and 55 will have zeros since you will be requesting the waiver of the penalty.

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4 Replies
dmertz
Level 15

Was 70 1/2 last year - missed the 4/1/17 RMD deadline by 4 days - distribution taken 4/4/17. Do I complete a form 5329 for 2016 or 2017?

2017 Form 5329.

That it should be reported on the 2017 Form 5329 and not the 2016 Form 5329 is not at all apparent.  It comes down to one statement in the instructions for Form 5329, "The tax is due for the tax year that includes the last day by which the minimum required distribution must be taken."  Since the last day in this case was April 1, 2017, it means that the tax would be due for 2017 and that the missed distribution would be reported on a 2017 Form 5329.  Of course you'll request a waiver of the penalty on that form based on now having made the late distribution.  You'll include this with your 2017 tax return.

Lines 52 and 53 of the 2017 Form 5329 will include your 2017 RMD required to be taken by the end of this year.  Lines 54 and 55 will have zeros since you will be requesting the waiver of the penalty.

dmertz
Level 15

Was 70 1/2 last year - missed the 4/1/17 RMD deadline by 4 days - distribution taken 4/4/17. Do I complete a form 5329 for 2016 or 2017?

You'll note that the text for line 52 of Form 5329 doesn't accurately describe the entry in this case.  Read line 52 of 2017 Form 5329 as saying "in 2017," not "for 2017."

Was 70 1/2 last year - missed the 4/1/17 RMD deadline by 4 days - distribution taken 4/4/17. Do I complete a form 5329 for 2016 or 2017?

Note also that when you do your 2017 tax return (next year) you will have a 1099-R to enter that will be the total of both your 2016 and 2017 RMD's.   When asked if you took all of the 2017 RMD say no and then you will get asked how much was taken and how much was missed.  TurboTax will add the 5329 form and ask for your explanation.
**Disclaimer: This post is for discussion purposes only and is NOT tax advice. The author takes no responsibility for the accuracy of any information in this post.**
Anonymous
Not applicable

Was 70 1/2 last year - missed the 4/1/17 RMD deadline by 4 days - distribution taken 4/4/17. Do I complete a form 5329 for 2016 or 2017?

Thanks to both of you - very confusing instruction (IRS) I thought - appreciate you straightening me out.
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