The answer can be yes or no

Two inherited accounts can both be subject to the 10-year rule and still have different requirements in years 1 through 9. The dividing line is the original owner’s required beginning date. That date is the point at which the owner was required to start lifetime RMDs under the applicable rules.

Owner died before the required beginning date

If a designated beneficiary is subject to the 10-year rule and the owner died before the required beginning date, Publication 590-B says no distribution is required for a year before the tenth year solely because of that 10-year rule. The account must still be fully distributed by the end of the tenth calendar year after the year of death.

This gives the beneficiary timing flexibility, but it does not make tax planning automatic. A large traditional IRA left untouched for nine years could create a very large taxable distribution in year 10. The law permits timing flexibility in this branch; it does not promise that waiting is tax-efficient.

Owner died on or after the required beginning date

If the owner died after RMDs had already begun, the final regulations generally require continued annual distributions to a non-eligible designated beneficiary while the 10-year clock is running. The account also must be fully emptied by the end of year 10. These are two simultaneous constraints, not alternatives.

The annual RMD is not a simple equal division over ten years. When the owner died on or after the required beginning date and there is a designated beneficiary, Publication 590-B directs the beneficiary to use the longer of the beneficiary’s single life expectancy and the owner’s remaining life expectancy. In regulatory terms, the calculation uses the greater applicable denominator. The beneficiary’s initial life expectancy is generally measured using the beneficiary’s age in the calendar year after death; the owner-side life expectancy begins with the owner’s age in the year of death. Each is then reduced under the post-death rules for later years.

That distinction matters when the beneficiary is older than the owner. In that case, the owner’s remaining life expectancy can produce the larger denominator and therefore the smaller annual minimum. A custodian may supply the calculation, but the beneficiary should keep the age inputs, prior-year balance, and denominator rather than saving only the final dollar amount.

Why older articles may say something different

After the SECURE Act, there was substantial uncertainty about whether annual RMDs were required inside the 10-year period when the owner had died after the required beginning date. IRS transition notices gave relief from the excise tax for certain missed distributions in 2021 through 2024. That relief was transitional, not a statement that annual RMDs would never apply.

The final regulations were published in 2024 and apply to RMDs for calendar years beginning on or after January 1, 2025. A beneficiary reading an older article should check its publication date and whether it reflects those final regulations.

Three facts to get in writing

  • The date of death and the owner’s age/date of birth.
  • Whether the custodian or former plan treated the owner as having reached the required beginning date.
  • The year-end account balance used for any beneficiary RMD calculation.

These facts are more useful than asking a custodian only, “Am I under the 10-year rule?” because that single label does not resolve the annual-RMD issue.

How to tell whether the owner had reached the required beginning date

Do not use a rough memory such as “Dad was in his seventies, so he must have been taking RMDs.” The required beginning date changed under recent retirement legislation, and employer plans can have retirement-related timing rules that differ from IRAs. Use the owner’s date of birth, account type, employment status where relevant, and actual plan or IRA records.

For an IRA, prior-year Forms 1099-R and custodian statements may show that lifetime RMDs had begun, but the absence of a distribution does not prove that no RMD was required. The legal date should be determined from the applicable rule for the owner’s year and account.

An annual RMD does not satisfy the year-10 requirement by itself

A common operational mistake is to take only the custodian-computed annual minimum for nine years and assume the account will naturally reach zero. It may not. Investment growth can leave a substantial balance, and the annual life-expectancy calculation was not designed to guarantee that the account is empty by the tenth-year deadline. The final year therefore needs its own balance review.

What to do when two institutions give different answers

If an inherited account has moved between custodians, the receiving institution may not have every historical fact. Ask each institution to state the assumption behind its answer. Then compare the answer with Publication 590-B and the final regulations. The most useful written response is one that identifies the owner’s required beginning date, beneficiary category, prior-year balance, and denominator used.

Transition relief should be documented, not guessed

For affected 2021–2024 distributions, Notice 2024-35 and earlier notices can matter. Keep a copy of the notice or tax-adviser explanation in the account file if a historical year was treated as relieved. That prevents a later reviewer from assuming a missing distribution was simply overlooked.