How RMDs Are Reported to the IRS: Forms 1099-R, 1040, and Waivers

Required minimum distributions are reported to the IRS through a two-sided paper trail: your custodian files Form 1099-R showing what you withdrew, and you carry those figures onto Lines 4a and 4b of your Form 1040. If you took less than required, you calculate and self-report the excise tax on Form 5329 and file it with your return. The IRS doesn’t send a bill for a shortfall, and the custodian doesn’t confirm you took enough. Both jobs sit with you.

Form 1099-R From Your Custodian

Form 1099-R is the document your financial institution uses to report retirement distributions to both you and the IRS.¹ Your copy must arrive by January 31 following the year of the distribution, and a copy goes to the IRS shortly after.² Because the agency has its own copy, it can cross-check your return against what the custodian reported.

Four boxes carry the weight for RMD reporting:

Box 1, Gross Distribution, shows the total amount withdrawn during the tax year. This is the figure that counts toward satisfying your RMD, whether or not all of it is taxable.
Box 2a, Taxable Amount, shows the portion subject to income tax. For most people taking RMDs from traditional IRAs or employer plans funded with pre-tax money, Box 2a matches Box 1. If the custodian can’t determine the taxable portion, they check the “Taxable amount not determined” box and leave the calculation to you.
Box 4, Federal Income Tax Withheld, shows any amount withheld before the money reached you. You claim it on your Form 1040 the way you’d claim paycheck withholding.
Box 7, Distribution Code, tells the IRS what kind of distribution this was. Code 7 is a normal distribution at age 59½ or older. Code 4 is a distribution from a deceased owner’s account. Code G is a direct rollover.

Your custodian does not confirm that your withdrawal met the full RMD requirement. They report only what you took. Whether that amount satisfies the rule is on you.

Moving the Numbers to Form 1040

IRA distributions go on Lines 4a and 4b of Form 1040. Line 4a gets the gross amount from Box 1 of your 1099-R. Line 4b gets the taxable amount from Box 2a. For most retirees those two numbers are identical, because the full RMD is taxable.

The picture changes if you’ve ever made non-deductible contributions to a traditional IRA. Part of every distribution is a return of money you already paid tax on. When the custodian marks “Taxable amount not determined,” you calculate the tax-free share yourself using Form 8606, and only the taxable remainder goes on Line 4b. Keep meticulous basis records. Failing to file Form 8606 when required carries a $50 penalty, but the larger risk is losing track of your basis and paying tax twice on the same money.³

If a distribution was a direct rollover, coded G in Box 7, the full amount still goes on Line 4a. Line 4b is zero, and you write “Rollover” beside it. An RMD itself cannot be rolled over. You have to take the required amount in cash before rolling anything else.

One timing note worth flagging: you can delay your very first RMD until April 1 of the year after you turn 73, but every RMD after that is due by December 31 of its own calendar year.⁴ If you use the delay, you’ll receive two 1099-Rs the following year (one for each distribution) and report both on the same Form 1040.

Qualified Charitable Distributions

A qualified charitable distribution transfers money directly from your IRA to an eligible charity. The amount counts toward your RMD and stays out of your taxable income. The annual limit was $108,000 per person for 2025 and adjusts for inflation.⁵

Reporting the QCD is where people get tripped up. Your custodian reports it in Box 1 of Form 1099-R like any other distribution. There is no special code identifying it as a QCD.⁶ Looking at the form alone, the whole distribution appears taxable.

You fix it on the 1040. Put the full distribution on Line 4a. On Line 4b, enter zero, or the reduced taxable amount if only part of the distribution was a QCD. Write “QCD” next to Line 4b.⁶ If you also took other IRA distributions the same year, Form 8606 may need to come along with the return. Hold on to the charity’s written acknowledgment. The IRS won’t see the QCD flagged anywhere on the 1099-R and relies on your return to get it right.

Multiple IRAs and Inherited Accounts

If you own more than one IRA, you calculate each account’s RMD separately but can take the combined total from whichever IRA or mix of IRAs you choose.⁴ The aggregation rule applies only to IRAs. A 401(k) and a 457(b) each require their own withdrawal from that specific plan.

The reporting wrinkle: even if you satisfy every IRA RMD from a single account, you’ll still receive a 1099-R from each IRA custodian, reporting either a distribution or a zero. You reconcile them all on Form 1040. Your total RMD obligation across all IRAs should be met or exceeded by the total distributions on the combined 1099-Rs, even though the money came from one account.

Inherited accounts have their own reporting details. If you inherit an IRA from someone other than your spouse, the custodian issues a 1099-R in the deceased owner’s name with you listed as beneficiary. Box 7 should show Code 4, indicating a distribution due to death. That code tells the IRS the 10% early withdrawal penalty doesn’t apply, whatever your age. You report the amounts on your own Form 1040 on Lines 4a and 4b the same way you would a personal RMD, and the Code 4 handles the penalty exemption automatically.

Reporting a Missed or Short RMD

If you don’t take the full amount by the deadline, the IRS imposes an excise tax of 25% on the shortfall, meaning the difference between what you should have withdrawn and what you actually did.⁷ If you correct the shortfall within two years, the rate drops to 10%.⁴

You self-report this penalty on Form 5329, filed with your Form 1040 for the year the RMD was due.⁸ You calculate the shortfall, apply the rate, and enter the figure yourself.

Requesting a Waiver

The IRS can waive part or all of the excise tax if the shortfall came from a reasonable error and you’re fixing it. Complete Form 5329 with the shortfall amounts as usual, then write “RC” on the dotted line next to the penalty line along with the amount you want waived. Reduce the penalty line by that amount and attach a written explanation of what went wrong and what you’ve done to correct it.⁸

Common reasonable-cause explanations include serious illness, a custodian error that held up the distribution, or a death in the family near year-end. The IRS tends to be forgiving when the taxpayer has already withdrawn the missed amount and the failure wasn’t willful. Take the corrective distribution before filing the waiver request. It strengthens the case.

If Your 1099-R Is Wrong or Missing

If the amount on your 1099-R is off, the distribution code is wrong, or the form never arrives, start with your custodian. If you haven’t received a corrected form by the end of February, call the IRS at 800-829-1040.⁹

The IRS will contact the custodian and send you Form 4852, a substitute for the missing or incorrect 1099-R. You can file your return using Form 4852 with estimated figures. If a corrected 1099-R shows up later with different numbers, file an amended return on Form 1040-X.10

1
Internal Revenue Service. About Form 1099-R, Distributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc.
2
Internal Revenue Service. General Instructions for Certain Information Returns (2025)
3
Internal Revenue Service. Instructions for Form 8606 (2025)
4
Internal Revenue Service. Retirement Plan and IRA Required Minimum Distributions FAQs
5
Internal Revenue Service. Publication 526 (2025), Charitable Contributions
6
Internal Revenue Service. Seniors Can Reduce Their Tax Burden by Donating to Charity Through Their IRA
7
Office of the Law Revision Counsel. 26 U.S. Code 4974 – Excise Tax on Certain Accumulations in Qualified Retirement Plans
8
Internal Revenue Service. Instructions for Form 5329 (2025)
9
Internal Revenue Service. Topic No. 154, Form W-2 and Form 1099-R (What to Do if Incorrect or Not Received)
10
Internal Revenue Service. Topic No. 154, Form W-2 and Form 1099-R (What to Do if Incorrect or Not Received)