late RMD - which age factor to use

[M Norton]

401(k) plan participant turned age 70 1/2 in 2018.  Attained age in 2018 was 71.  RMD should have been made by 4/1/2019.  Because it will be late, earnings will also have to be calculated.

The distribution is being made for 2018 when attained age was 71.  The distribution will actually be made in 2019 when attained age will be 72.  

If attained age in 2019 is used to determine the factor for the first RMD for 2018, then the same factor would be used again to calculate the RMD for 2019.

So the question is: which age factor to use to calculate the first RMD? 

Thanks!

[spiritrider]

The attained age (71) in the year the participant turned 70.5 (2018) will be used. Earnings are never considered with regards to late RMDs. An age 71 RMD based on the 12/31/2017 account balance should be taken as soon as possible.

Then a Form 5329 should be filed requesting a waiver of the 50% penalty for reasonable cause.They should include an explanation of any "reasonable cause", such as I didn't know, I didn't remember or the dog ate my RMD form. Also, include proof that the 2018 RMD was taken. The waiver will almost certainly be granted by the IRS if the Form 5329 instructions for a waiver request are followed to the letter. The participant may or may not get a response from the IRS.

An additional age 72 RMD with be required by 12/31/2019 based on the 12/31/2018 balance. Both RMDs will be taxable in 2019.