Notice 2022-53

I don't think I've seen any discussion on this...the notice says that the excise tax will not apply for distributions not taken in 2021 or 2022 under the 10 year rule. 

But I don't think they said when those distributions must be taken - that is, do they get pushed to 2023, or do you do the RMDs over the remaining 10 years, or what? Or did I miss something? The notice makes reference to the intent to publish final regs and I guess that's where the answers will lie. Seems weirdly incomplete though.

Honestly, I just quickly skimmed it, until such time as I have to deal with it on a real-life case. But I just sort of "assumed" that the distributions would have to be taken in 2023 as you would with "regular" missed distributions.

Thanks. Ilene's article, just out, says it's up in the air.

"We don’t know yet whether the final regulations will require a “make-up” distribution of the 2021 and 2022 specified RMDs as part of the 2023 RMD."