IRS Issues Notice on Certain Required Minimum Distributions for 2024

The IRS recently issued Notice 2024-35, which updates and extends the transition relief provided in Notice 2023-54, which addressed changes made by the SECURE Act and the SECURE 2.0 Act in required minimum distribution (RMD) requirements for qualified plans such as 401(k) plans, IRAs, Roth IRAs, 403(b) plans, and 457(d) eligible deferred compensation plans. For further information on prior Notice 2023-54, please see our August 3, 2023, Compliance Corner.)

The SECURE Act originally increased the age for determining an individual’s required beginning distribution date from 70 1/2 to age 72. The SECURE 2.0 Act then increased that to age 73 beginning January 1, 2023. Periodically, the IRS has issued transition relief to help plan administrators and others implement these changes to the RMDs. For example, Notice 2023-54 updated previous relief relating to otherwise required RMDs to beneficiaries after the deaths of participants (otherwise known as “specified RMDs”) in 2020 and 2021 to include the same for otherwise required RMDs related to participant deaths in 2022.

Notice 2024-35 essentially extends this relief for another year, meaning that plans will not be treated as failing to satisfy the RMD rules for the failure to make a specified RMD in 2024 related to a participant’s death in 2023, nor will a taxpayer be subject to an excise tax for having failed to take a specified RMD.

Employers should be aware of this extension of the previous transition relief.

Notice 2024-35, Certain Required Minimum Distributions for 2024 »