There’s an Exception to the “No RMDs” Rule for Roth IRAs. Get It Wrong, and You Could Face a 25% Tax Bill.

If you own a Roth IRA, you already know the headline perk: no required minimum distributions during your lifetime. The account grows tax-free for as long as you live, and no IRS-mandated withdrawal schedule ever forces your hand. There is, however, a buried clause that catches families flat-footed every year. The moment you die, that protection ends. Whoever inherits your Roth IRA faces a required withdrawal schedule, and missing it triggers a 25% excise tax on the amount they should have taken out. The IRS has also been sharpening its enforcement tools, making the risk of a missed deadline more consequential than ever.

Inherited Roth IRAs have a clock

While you are alive, your Roth IRA is fully RMD-free. Once you pass, most beneficiaries fall under what the IRS calls the 10-year rule. The inherited Roth IRA must be fully drained within 10 years of the original owner’s death. The tax-free status of qualified withdrawals survives the transfer to a beneficiary. The unlimited runway does not.

That was not always the case. Before the SECURE Act took effect in 2020, non-spouse beneficiaries could spread inherited IRA distributions across their own lifetimes, a strategy known as the “stretch IRA.” A 40-year-old inheriting a parent’s account could take small, manageable distributions over decades, letting the bulk of the balance keep compounding. Congress ended that option for most heirs, replacing it with the hard 10-year deadline now in force.

The legal foundation

The 10-year rule was written into the SECURE Act of 2019 and applies to most non-spouse beneficiaries who inherit from an owner who died in 2020 or later. The Treasury Department and IRS then issued final regulations (T.D. 10001) on July 19, 2024, clarifying key implementation details and making the rules fully effective beginning January 1, 2025. The underlying authority is Internal Revenue Code §401(a)(9), which governs distributions from inherited retirement accounts. Separately, SECURE 2.0 lowered the penalty for missed required distributions from 50% to 25% of the shortfall, with a further reduction to 10% if you self-correct within the IRS’s two-year correction window.

One important piece of recent history: the IRS issued a series of penalty-relief notices (Notices 2022-53, 2023-54, and 2024-35) covering tax years 2021 through 2024, waiving excise taxes on missed inherited IRA distributions while the rules remained unsettled. That grace period is now closed. Beginning with the 2025 tax year, missed distributions trigger the full 25% excise tax, and the IRS has enhanced its detection systems for missed RMDs, making oversight more active than it was during the waiver years.

Who it applies to, and who escapes it

The 10-year rule targets non-eligible designated beneficiaries: adult children, grandchildren, siblings, friends, and most non-spouse heirs. A smaller group called eligible designated beneficiaries receives more favorable treatment. That group includes a surviving spouse (who can roll the Roth into their own IRA and sidestep RMDs entirely), a minor child of the deceased (until that child turns 21, at which point the 10-year clock begins), a disabled or chronically ill beneficiary, and any beneficiary no more than 10 years younger than the original owner. Beneficiaries who are older than the deceased owner also fall outside the 10-year rule. For everyone outside that protected group, the clock starts the year after the owner dies.

One clarification worth noting: the 2024 final regulations set age 21 as the universal threshold for minor children, replacing a prior approach that deferred to state law. Most states set the age of majority at 18, while a handful used 19 or 21, and that variation created genuine confusion for families navigating the rules. A single nationwide line drawn at 21 resolved the inconsistency.

How to use the window without blowing it up

For an inherited Roth IRA, the IRS gives you genuine flexibility inside the 10-year window. Because the original Roth owner never had a Required Beginning Date, the account is always treated as a pre-RBD death for inherited-IRA purposes. That means no required annual withdrawals during years 1 through 9. You can take a little each year, skip distributions entirely for nine years and drain the account in year 10, or choose any combination in between. Here is a practical framework for navigating the window:

1. Confirm whether the original owner held the Roth for at least five years. If yes, withdrawals of earnings come out completely tax-free. If the five-year clock had not yet run, earnings may remain taxable until it does.
2. Map your own tax bracket over the next 10 years. If you are mid-career and in a high-earning phase, spreading tax-free Roth pulls across several years is a smarter approach than a single large withdrawal late in the window.
3. Watch for the “kiddie tax” if the beneficiary is a full-time student under age 23. Investment income for those filers, including IRA distributions, can be taxed at the parents’ marginal rate rather than the student’s own lower rate, which changes the math on when to take money out.
4. Avoid the year-10 lump sum trap. Even though Roth distributions are typically tax-free, a single large withdrawal can complicate Medicare IRMAA surcharges, financial-aid calculations, and any non-qualified portion that remains taxable. In 2026, IRMAA kicks in for single filers whose 2024 modified adjusted gross income exceeded $109,000, pushing the total monthly Part B premium from the standard $202.90 to $284.10 at the first bracket alone. A retiree who manages income carefully to stay at or below $109,000 keeps that standard rate intact.
5. Mark December 31 of year 10 on the calendar. That is the hard deadline. The account must show a zero balance by then.

For those still in the accumulation phase, there is also a planning opportunity on the owner’s side: converting a traditional IRA to a Roth before death can pass a tax-free inherited account to heirs rather than a fully taxable one. That conversion cannot happen after the fact on a non-spousal inherited IRA, so it requires action while the original owner is still alive.

The 25% penalty, and how it actually works for Roths

For an inherited Roth IRA, the penalty exposure comes down to one critical date: the end of year 10. Because Roth owners have no Required Beginning Date under IRC §408A(c)(5), beneficiaries of inherited Roth IRAs face no required annual distributions in years 1 through 9. The 10-year rule still applies in full, but the only way to trigger the 25% excise tax is to leave money in the account past December 31 of year 10. Whatever balance remains after that deadline is subject to the 25% charge. Self-correcting and filing Form 5329 within the two-year correction window reduces that rate to 10%. In cases of inadvertent error, the IRS also has discretion to waive the penalty entirely when the account holder takes the missed distribution and files a reasonable-cause explanation with Form 5329, though a waiver is never guaranteed.

The more complex annual-RMD scenario applies to traditional inherited IRAs where the original owner had already passed their Required Beginning Date before dying. In those cases, beneficiaries face required annual withdrawals in years 1 through 9 and full depletion by year 10, creating multiple potential penalty events across a decade. For a pure inherited Roth, the trap is simpler: one date, one deadline, one entirely avoidable reason an account built over decades of tax-free compounding gets penalized on the way out. That reason is not knowing the rule existed.

This is general education, not personalized financial advice.

Editor’s note: This pass corrected the Medicare Part B premium description in the IRMAA section to clarify that $202.90 is the standard monthly premium paid at or below the $109,000 income threshold for single filers, and that crossing that line raises the total Part B premium to $284.10 per month at the first IRMAA bracket. It also added that the IRS has enhanced its detection systems for missed RMDs, and incorporated the IRS’s discretionary penalty-waiver path for inadvertent misses when Form 5329 is filed with a reasonable-cause explanation.

Contact [email protected] for any questions or corrections.