Missed RMD for 2018

[Cynchbeast]

We have client who missed paying an RMD for 2018 (seems to have been legitimate error since person normally handling this was out for illness).  Participant will take RMD now - my questions:

1. Form 5329 reports missed RMD.  This goes with his 1040?  If taxes already filed, does he amend 1040?  He will attach letter of explanation; does he pay 50% penalty with 5329 or not?
2. If 2018 RMD taken now (Jan, 2019), do we prepare 1099-R for 2018 or 2019?
3. Anything else I am missing?  Does the sponsor have to report this?

[Lois Baker]

Article from today's BenefitsLink Retirement Plans newsletter might be of interest here:

https://www.morningstar.com/videos/904333/what-to-do-if-you-missed-your-rmd.html

[Cynchbeast]

Good article - thank you.  So I am assuming we issue no 1099-R for 2018, and the 1099-R for 2019 will reflect both years' RMDs?

And what does the participant do if he has already filed his (1040) tax return?  Obviously filed without the 5329.

[Lou S.]

I will point out that the article is for IRAs. Plans can be a bit different. I think you have an operational failure that you can correct under VCP (not sure if this one is eligible for self correction).

If the participant filed without the 5329, I would assume they would need an amended tax return.