Which 10-year regime are you in?

There are two versions of the 10-year rule, and everything flows from one fact: had the original owner started taking their own RMDs before they died? That means their required beginning date (generally April 1 of the year after turning 73, or 72 or 70 and 1/2 under older rules) had passed.

  • Owner died on or after their required beginning date: annual RMDs in years 1 through 9 plus the account fully emptied by December 31 of year 10. This is the regime most people get wrong, because from 2020 through 2024 the IRS was not enforcing the annual requirement while it finalized the regulations. The final regulations (T.D. 10001, July 2024) settled it, and transitional penalty relief ended with the 2024 tax year.
  • Owner died before their required beginning date: no annual RMDs, but the account must still be fully emptied by December 31 of year 10. You choose the timing. Many beneficiaries spread withdrawals deliberately rather than waiting until year 10, for the tax-bunching reason below.
The year-10 balloon. Taking only the annual minimums for nine years and emptying the account in year 10 can push a large lump of ordinary income into a single tax year, often at a higher marginal rate. The annual RMD is a floor, not a strategy. Consider modeling roughly even withdrawals across the full period, or concentrating larger withdrawals in lower-income years.

Worked example: the math, step by step

The following is a hypothetical illustration with round numbers, so you can see exactly how the annual-RMD arithmetic works under the 10-year rule. It is not your situation and not advice; your actual factor comes from the IRS Single Life Table based on your age in year 1.

Illustration. You are 50 when you inherit a $400,000 traditional IRA from your mother, who died in 2021 at age 78, after starting her own RMDs. Your regime: the 10-year rule with annual RMDs. Year 1 is 2022, and the account must be empty by December 31, 2031.

Your factor sequence. Your Single Life Table factor at age 50 is approximately 36.2. Subtract one each year: year 2 (2023) is 35.2, year 3 (2024) is 34.2, year 4 (2025) is 33.2, and so on.

Year 1 RMD. The account balance on December 31, 2021 was $400,000. Your 2022 RMD is $400,000 ÷ 36.2 = $11,049.72.

Year 2 RMD. Suppose the balance on December 31, 2022 is $380,000 (after your withdrawal and market movement). Your 2023 RMD is $380,000 ÷ 35.2 = $10,795.45.

Year 10. Whatever remains on December 31, 2030 must come out by December 31, 2031, on top of the nine annual RMDs already taken. Note that these annual RMDs are far smaller than an even 10-way split, which is exactly why planning the full schedule matters.

Missed annual RMDs and the relief that ended

From 2021 through 2024, the IRS issued a series of notices (2022-53, 2023-54, and 2024-35) waiving the penalty for certain missed annual RMDs under the 10-year rule while the final regulations were pending. That transitional relief ended with the 2024 tax year. From the 2025 tax year onward, a missed annual RMD is subject to the excess accumulations excise tax: generally 25% of the shortfall, reduced to 10% if corrected within the correction window. If you skipped annual RMDs in 2025 thinking the old waiver still applied, correct it promptly and document everything.

What to do first

  1. Confirm whether the owner died on or after their required beginning date. This determines whether annual RMDs apply.
  2. Identify year 1 (the calendar year after the year of death) and your year-10 deadline. Everything is measured from those two dates.
  3. Calculate this year's annual RMD from the Single Life Table using your age in year 1, minus one per year elapsed. Use the custodian-confirmed factor.
  4. Model the full 10-year withdrawal plan, not just this year's minimum, and watch for the year-10 balloon.

Calculate my 10-year rule schedule

For the full treatment, including the annual-RMD regime, see the in-depth guide: The 10-Year Rule With Annual RMDs. For the no-annual-requirement regime, see The 10-Year Rule Without Annual RMDs.

Sources

Frequently asked questions

Does the 10-year rule require annual RMDs?

Only if the owner died on or after their required beginning date. If the owner died before starting RMDs, there is no annual requirement, but the account must still be empty by the end of year 10.

How is the annual RMD calculated under the 10-year rule?

Use your own age and the IRS Single Life Table: your factor in year 1, minus one each subsequent year. Each year's RMD is the prior December 31 balance divided by that year's factor.

When does year 1 start for the 10-year rule?

Year 1 is the calendar year after the year of the owner's death. If the owner died in 2021, year 1 is 2022 and the account must be empty by December 31, 2031.

What is the penalty for missing an annual RMD under the 10-year rule?

Generally 25% of the shortfall, reduced to 10% if corrected within the correction window. The transitional relief for 2021 through 2024 has ended.

Do I have to take equal amounts each year under the 10-year rule?

No. The annual RMD is a floor, not a withdrawal strategy. You may take more in any year, and many beneficiaries deliberately spread withdrawals to avoid the year-10 balloon.

Does the 10-year rule apply to an inherited Roth IRA?

Yes, the 10-year deadline applies, but there are generally no annual RMDs on an inherited Roth IRA, and qualified distributions remain tax-free.

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Disclaimer. Educational purposes only, not tax, legal, or financial advice. Inherited IRA rules are fact-specific and the 10-year rule interacts with the owner's RMD status at death, your beneficiary category, and account titling. Verify everything with a qualified tax professional before acting. The authoritative sources are IRS Publication 590-B, the IRS RMD FAQs, and the 2024 final regulations.