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The IRS wants a missed required withdrawal reported on Form 5329

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A missed required withdrawal does not end with the December 31 deadline. The shortfall has to be reported to the Internal Revenue Service on a separate form, and taking the money out late does not make the miss disappear from the return.

That form is Form 5329, titled Additional Taxes on Qualified Plans (Including IRAs) and Other Tax-Favored Accounts. The IRS describes it on its Form 5329 page as the place to report extra taxes on IRAs, workplace plans and several other tax-favored accounts.

What exactly does an account owner with a missed required withdrawal have to put on that form, and does catching up late change the answer?

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Form 5329 is the report, not the payment

The IRS page on required minimum distributions, last reviewed April 8, 2026, says an account owner who does not take the full amount may have to file Form 5329. It adds that a 25% excise tax can apply to the amount not distributed as required, and that the rate is 10% if the money is withdrawn within two years.

An excise tax is a charge on a specific act. Here the act is leaving money in an IRA or workplace plan that the rules said should have come out.

Which tax year the miss belongs to

The Form 5329 instructions say the tax is owed for the year that includes the last day the withdrawal was due. A person who missed a December 31 deadline reports the shortfall for that calendar year, not for the year the catch-up check was cut.

The instructions now posted are the 2025 edition, dated November 19, 2025, and they apply to returns for 2025. A shortfall in 2026 goes on the 2026 version of the form, which comes with next year’s filing season.

The lines that count the shortfall

The instructions walk through Part IX of the form. Lines 52a and 52b take the amount that was required, and lines 53a and 53b take the amount that was actually distributed toward it.

Line 54 then shows the total excess accumulation, which is the IRS term for the shortfall. The instructions say the additional tax is 25% of that figure. Anyone who qualifies for the lower rate uses 10% instead.

For a trust or estate, the instructions say the amount also goes on Form 1041, Schedule G, line 8, with the words “From Form 5329” written beside it.

Taking the money late changes the rate

The IRS RMD page puts the lower rate at 10% when the shortfall is withdrawn within two years. The instructions are more specific. They say the reduced rate applies when the person takes a distribution of the shortfall and files a return that reflects the additional tax during what the IRS calls the correction window.

That window is not a plain two-year clock. The instructions say it ends on the earliest of three dates:

  • the date the IRS mails a notice of deficiency for the tax,
  • the date the tax is assessed, or
  • the last day of the second taxable year that begins after the end of the year in which the tax was imposed.

In other words, a late withdrawal helps most when it comes before the IRS acts on the miss.

Asking the IRS to waive the tax

The instructions say the IRS can waive part or all of the tax if the shortfall was due to reasonable error and the person is taking reasonable steps to remedy it. Publication 590-B, the IRS guide to IRA distributions, has its own sections titled “Request to waive the tax” and “Reporting the tax.”

The request is made on the form itself. The instructions say to fill in lines 52a and 52b and 53a and 53b, then write “RC” and the shortfall amount in parentheses on the dotted line next to line 54a or 54b. The person subtracts that amount from the total shortfall, attaches a statement explaining the error, and pays any tax still due on line 55.

Filing the form without a tax return

Someone who does not otherwise have to file an income tax return still has to send in Form 5329. The instructions say that if no 2025 return is required, the form is completed and filed by itself.

It goes to the place where a Form 1040, 1040-SR or 1040-NR would be filed, and the instructions say it cannot be filed electronically. Anyone in that spot is mailing paper, so the timing runs through the postal system. The full set of rules is in the instructions at IRS.gov, and the IRS required minimum distributions page covers who must take withdrawals and when.

Has the missed withdrawal been counted on Form 5329 yet?

A shortfall that is left off the return, or reported on the wrong year’s form, can leave a 25% charge sitting on a withdrawal that was already made late. Anyone who skips the waiver statement gives up the chance to have part or all of that tax set aside.

Cut Your Retirement Tax Bill: 12 Moves covers RMDs on time, without the 25% penalty or the first-year trap, and giving from an IRA straight to charity, left out of taxable income. It lays out the 12 moves with the form to use for each, including Form 5329, in 2026 numbers.

See the Form 5329 and charity-gift moves in Cut Your Retirement Tax Bill: 12 Moves →

This article was produced with AI assistance and edited for accuracy against the sources linked above.


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