Compliance Blog

Jan 14, 2009

IRA RMD Guidance; New Flood Form Unveiled

The IRS has released IRS Notice 2009-09 to help financial institutions report required minimum distributions (RMDs) for 2009.  As you may recall, President Bush recently signed the Worker, Retiree, and Employee Recovery Act of 2008, which waives RMDs for 2009.  The notice gives guidance on how to complete IRS Form 5498 and gives other tips.

Issuers of the 2008 Form 5498, IRA Contribution Information, should not put a check in Box 11. However, in recognition of the short amount of time to make programming changes, if a financial institution issues a 2008 Form 5498 with a check in Box 11, the IRS will not consider such form issued incorrectly solely because of the check in Box 11, provided the IRA owner is notified by the financial institution no later than March 31, 2009, that no RMD is required for 2009.

In addition, the RMD information required under Notice 2002-27, 2002-18 I.R.B. 814, need not be sent to IRA  owners for 2009. If a financial institution sends a separate RMD statement to an IRA owner, either initially or in response to the owner’s request for the financial institution to calculate the RMD for 2009, the financial institution must show the RMD for 2009 as zero (0). Alternatively, the financial institution may send the IRA owner a statement showing the RMD that would have been required but for the waiver of RMDs for 2009, along with an explanation of the waiver for 2009.

The IRS encourages all financial institutions to inform IRA owners who delayed taking their 2008 RMD until April 1, 2009, that they are still required to take that distribution.

Access Notice 2009-09 here.

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FEMA recently unveiled its new Standard Flood Hazard Determination Form.   (Unveil, perhaps is too strong a word.   This certainly isn't the new I-Phone.)  Access the FEMA press release here, which also contains a link to the new form.  To allow users of the Form time to update their systems to the new version, the effective date for mandatory use of the new Form will be June 16, 2009.