Who this applies to
All four of these must be true:
- You are a non-spouse beneficiary (child, grandchild, sibling, friend).
- You are not an eligible designated beneficiary (not disabled, not chronically ill, not 21-or-under child of the owner, not within 10 years of the owner's age).
- The original owner died on or after January 1, 2020.
- The owner died on or after their required beginning date, i.e., they had already started taking RMDs (generally April 1 of the year after turning 73, or 72/70½ under older brackets).
If the owner died before starting RMDs, you fall under a different regime, the 10-year rule with no annual requirement.
What you actually have to do
Two obligations, running in parallel:
- Years 1–9: take an annual RMD, calculated from the IRS Single Life Table (Table I, Publication 590-B) using your age. Find your life-expectancy factor for year 1, then subtract 1 from the factor each subsequent year.
- By December 31 of year 10 (counting from the year after death as year 1): the account must be fully emptied.
| Year | Your age | Factor | RMD (approx.) |
|---|---|---|---|
| 1 | 46 | 38.8 | $12,887 |
| 2 | 47 | 37.8 | ~$13,200* |
| 3 | 48 | 36.8 | ~$13,600* |
*Approximate, the actual RMD each year is that year's Dec 31 balance ÷ that year's factor. Balances move with markets and withdrawals.
And whatever remains at the end of year 10 comes out in one final distribution, which is why the annual minimums alone are rarely the right withdrawal strategy (see below).
Why everyone gets this wrong
From 2020 through 2024, the IRS itself wasn't sure, proposed regulations suggested annual RMDs, but enforcement was repeatedly waived while the rule was finalized. An entire cohort of beneficiaries reasonably concluded "I just have 10 years." The final regulations (TD 10001, July 2024) settled it: annual RMDs apply, and the transitional penalty relief ended with the 2024 tax year. From the 2025 tax year onward, a missed annual RMD faces the 25% excise tax on the shortfall (10% if corrected within two years).
What to do now
- Confirm the owner's RMD status at death, this determines everything.
- Calculate this year's annual RMD from the Single Life Table (not the Uniform Lifetime Table, that's for your own IRA).
- Check whether you missed annual RMDs for 2025, if so, correct quickly; the 10% reduced penalty window is two years.
- Plan the full 10-year withdrawal schedule, not just this year's minimum.