The IRS released proposed regulations on changes to the required minimum distribution (RMD) rules effective beginning in 2020. In a surprise move, the regulations require most designated beneficiaries to take annual RMDs within the ten-year distribution period if the original account owner died after the required beginning date (the SECURE Act is silent with respect to whether annual distributions are required). However, the IRS has yet to release guidance for clients who inherited accounts after the SECURE Act's effective date and before the regulations were issued. In other words, they don't address whether a client may be required to take a retroactive RMD for 2021. The proposed regulations themselves are effective January 1, 2022 (the existing regulations must be applied for 2021). For more information on the RMD rules that apply after an account owner's death, visit Tax Facts Online. Q 3902