Compliance
Compliance Alert: U.S. IRS Notice on Required Minimum Distributions and Proposed Regulations Withdrawal
Recent IRS notices change timing of required minimum distributions and withdraw old proposed regulations on joint & several liability—crucial developments for retirement savings and married filers.
By NomadicTax Research Team • 5-8 min read • March 12, 2026
## What Changed
- On **March 9, 2026**, the IRS issued **Bulletin No. 2026-11**, announcing that certain final regulations regarding **Required Minimum Distributions** (RMDs) under section 401(a)(9) will apply no earlier than **the 2026 distribution calendar year**, with some sections waiting until six months after the final rules are published. ([irs.gov](https://www.irs.gov/pub/irs-irbs/irb26-11.pdf?utm_source=openai))
- Concurrently, two earlier **proposed regulations** (from 2013 and 2015) concerning relief from joint and several tax liability under section 6015 and related to community property state law were **formally withdrawn**. No final rules will be issued without a renewed comment process. ([irs.gov](https://www.irs.gov/irb/2026-03_IRB?utm_source=openai))
## Who This Impacts
- **Retirement account holders and fiduciaries**, especially those managing distributions from 401(k)s, IRAs, and other tax-advantaged accounts, must follow existing RMD rules until the final version is issued and the effective date clarified.
- **Married taxpayers** in joint filing status, particularly in community property states (e.g., California, Texas), expecting relief under old proposals need to acknowledge that those changes are not moving forward in their original form. Relief requests under 6015 must follow existing regulations.
## Actionable Compliance Steps
- **Review distribution calendars** to ensure you’re meeting RMD deadlines per current law. Don’t rely on anticipated regulations until they’re finalized and published.
- **Joint liability relief**: If expecting relief for joint returns under community property situations, investigate current §6015 provisions and waivers rather than relying on withdrawn drafts.
- **Maintain thorough records**: For both RMD calculations and any joint liability or community property claims, keep documentation of incomes, spouses’ contributions/state property laws, and your attempts to claim relief.
## Example Scenarios
- *Scenario 1*: Mary holds IRAs and 401(k)s; she normally expects new regulations to ease her distribution burden. Since new rules are pending, she must still follow existing RMD rules for 2026 under current law.
- *Scenario 2*: Tom and Lisa live in a community property state and filed jointly. Tom hopes the withdrawn 2015/2013 guidance (if finalized) would reduce joint liability. They should instead explore relief under existing §6015 relief forms and seek legal advice.
## Key Takeaways
- Final regulations have **not yet taken effect**; many provisions remain subject to comment and further revisions.
- Taxpayers should **not presume changes**—conform to current law, but monitor forthcoming **Federal Register** postings for final regulations.
- Consult your tax or legal advisor if retirement distributions or spousal liabilities are central to your tax situation—misinterpretation could carry penalties, or irreversible tax effects.