2023-03-15
Notice 2023-23 provides guidance to financial institutions on reporting required minimum distributions (RMDs) for 2023 after the amendment to Code Sec. 401(a)(9) made by the “SECURE 2.0 Act of 2022” (SECURE 2.0 Act), P. L. 117-328, enacted on December 29, 2022. See IRS FAQ page.
Division T included a number of retirement savings provisions. Section 107 amended section 401(a)(9)(C) of the Code to delay the required beginning date applicable to section 401(a) plans and other eligible retirement plans described in section 402(c)(8), including individual retirement accounts and annuities (IRAs).
For an IRA owner who attains age 72 after December 31, 2022, and age 73 before January 1, 2033, the new required beginning date (that is, the date by which RMDs must begin) is April 1 of the calendar year following the calendar year in which the individual attains age 73, rather than April 1 of the calendar year following the calendar year in which the individual attains age 72.
This amendment to section 401(a)(9)(C) is effective for distributions required to be made after December 31, 2022, with respect to individuals who will attain age 72 after that date. As a result of this amendment, IRA owners who will attain age 72 in 2023 (that is, individuals born in 1951) will have a required beginning date of April 1, 2025, rather than April 1, 2024. This delay in the required beginning date means that these IRA owners (who, prior to enactment of the SECURE 2.0 Act, would have been required to take minimum distributions from their IRAs for 2023) will have no RMD due from their IRAs for 2023.