When the 5-year rule applies
The 5-year rule applies to a non-designated beneficiary (generally an estate, a charity, or a non-qualifying trust) when the original owner died before their required beginning date (before starting RMDs).
If the owner died on or after their required beginning date with a non-designated beneficiary, a different regime applies: annual distributions based on the deceased owner's remaining life expectancy (sometimes called the "ghost" rule), continuing until the account is empty. This is one of the least-understood corners of the RMD rules, professional guidance is strongly advised here.
What it requires
- The entire account balance must be distributed by December 31 of the calendar year containing the 5th anniversary of the owner's death.
- No annual minimum, distributions can be timed freely within the five years.
- The 25% excise tax applies to any amount still in the account after the deadline.
How this usually happens
- No beneficiary named. The IRA defaults to the estate, the most common way the 5-year rule gets triggered, and entirely avoidable with a beneficiary designation.
- Charity named directly. Charities don't pay the income tax, so bunching doesn't hurt them, but the 5-year deadline still governs.
- A trust that isn't "see-through." Only trusts meeting specific IRS requirements preserve the underlying individual's beneficiary treatment. A trust that fails the tests is a non-designated beneficiary. Trust drafting and beneficiary designations should be reviewed together, by an estate attorney, not just the IRA custodian.