What If My Gold IRA Misses an RMD?

A missed required minimum distribution from a self-directed gold IRA triggers a 25 percent excise tax on the shortfall under Internal Revenue Code Section 4974, reduced to 10 percent if the missed amount is withdrawn within 2 years and reported on Form 5329. The previous 50 percent rate, in effect before 2023, was lowered by the SECURE 2.0 Act. This guide walks through the current penalty math, the correction window, the Form 5329 procedure, the reasonable cause waiver, and the operational steps a gold IRA holder takes to settle the shortfall using physical metal. It does not advise when or how much to distribute. Consult your tax advisor for your specific situation.

How a gold IRA RMD gets missed

A required minimum distribution applies to a traditional self-directed IRA holding physical precious metals starting in the year the account holder reaches age 73, under the SECURE Act 2.0 schedule. The first RMD is due by April 1 of the year after the triggering birthday, and each subsequent RMD is due by December 31 (IRS RMD overview). Roth IRAs are not subject to lifetime RMDs for the original account holder.

The mechanics differ from a brokerage IRA. A self-directed precious metals IRA holds physical bullion at an IRS-approved depository under 26 U.S. Code Section 408(m). Settling the RMD requires either liquidating part of the metal through the dealer with cash returned to the custodian, or taking an in-kind distribution that ships physical metal to the account holder. Neither happens automatically. The account holder must initiate the request, sign the custodian forms, and confirm the dealer or depository instructions.

RMDs get missed in this setup for operational reasons more often than for financial ones. The account holder may not have received a clear December reminder from the custodian. The dealer quote may have taken longer than expected to settle. The in-kind shipping logistics may have crossed the December 31 deadline. A new custodian after a transfer may not have inherited the prior-year December 31 fair market value used for the calculation. Each is a paperwork sequence rather than a discretionary choice, and each can produce a missed RMD.

The current 25 percent excise tax and the 10 percent correction rate

The IRS imposes an excise tax on the amount that should have been distributed but was not. Under Internal Revenue Code Section 4974, as amended by the SECURE 2.0 Act of 2022, the rate is 25 percent of the shortfall. The rate drops to 10 percent if the shortfall is withdrawn within a 2-year correction window and Form 5329 is filed for the missed year. The pre-2023 rate was 50 percent and applied to all missed amounts regardless of correction speed (IRS RMD page).

The IRS canonical language on the current page reads: “If you don’t take any distributions, or if the distributions are not large enough, you may have to pay a 25% excise tax on the amount not distributed as required (10% if withdrawn within 2 years).” That sentence anchors the rule. The 10 percent rate is conditional on the correction sequence, not automatic on the calendar.

The excise tax is in addition to the ordinary income tax on the distribution itself when it is eventually taken. A traditional IRA distribution remains taxable income on Form 1040 in the year received. A Roth IRA missed RMD scenario applies only to inherited Roth IRAs and certain prior-rule Roth designated accounts inside employer plans, not to the original Roth IRA holder.

The 2-year correction window

The 2-year correction window starts on the date the RMD was originally due. For an RMD that was supposed to be taken by December 31, 2025, the correction window for the 10 percent rate runs through December 31, 2027. The shortfall must be withdrawn during that window and Form 5329 must be filed for the missed year, generally with the federal income tax return for the year the shortfall was withdrawn (Form 5329 instructions).

The window applies per missed year. A multi-year stretch of missed RMDs creates multiple windows running on different calendars. Each year is reported on its own Form 5329. Each window starts on its own due date. A taxpayer who corrects all missed amounts in a single later year may qualify for the 10 percent rate on years still inside their window and the 25 percent rate on older missed amounts.

Form 5329: reporting the shortfall

Form 5329, titled “Additional Taxes on Qualified Plans (Including IRAs) and Other Tax-Favored Accounts,” is the IRS form used to report and calculate the excise tax on a missed RMD (IRS Form 5329 page). Part IX of the form, “Additional Tax on Excess Accumulation in Qualified Retirement Plans,” covers the missed RMD calculation.

1. Identify the missed year and amount. Pull the December 31 prior-year fair market value statement from the custodian. Apply the IRS Uniform Lifetime Table factor for your age that year. The result is the dollar amount that should have been distributed.
2. Calculate the shortfall. Line 52 lists the required amount. Line 53 lists the amount actually taken. Line 54 is the difference, which is the shortfall.
3. Apply the rate. Multiply the shortfall by 25 percent for the standard rate or 10 percent if the shortfall has been withdrawn within the 2-year correction window. Line 55 carries the result.
4. File for the missed year. Form 5329 is generally filed with Form 1040 for the year the shortfall was withdrawn, or as a standalone return if no Form 1040 is otherwise required. The Form 5329 instructions for the relevant year govern.
5. Attach a waiver statement if pursuing reasonable cause. The waiver request is entered on Line 54 with the code RC and the amount of the waiver, with a written explanation attached.

The form can be filed for prior years separately when a missed RMD is discovered late. Each year is its own filing. The amended return process on Form 1040-X is not required if Form 5329 is filed as a standalone for the missed year, though state tax filings may have parallel requirements that vary by state. Consult your tax advisor for your specific situation.

Reasonable cause waiver request

The IRS may waive the excise tax if the shortfall was due to reasonable error and the account holder takes reasonable steps to correct it. The waiver authority is in Internal Revenue Code Section 4974(d) and is restated in the Form 5329 instructions. The waiver is requested by the taxpayer and reviewed individually by the IRS. There is no automatic grant.

The procedure has three components. The first is the correction itself, which means actually taking the missed distribution before submitting the waiver request. The second is the Form 5329 entry, where the taxpayer enters RC and the amount of the requested waiver on the line for the excise tax, rather than paying the tax outright. The third is the attached written statement, which describes the reasonable cause and the corrective steps taken.

Reasonable cause examples accepted by the IRS in past guidance include serious illness, death of a family member responsible for handling the account, custodian error in reporting the December 31 fair market value, and isolated procedural mistakes by a new account holder unfamiliar with the RMD trigger. Routine forgetfulness or general inattention is generally not accepted as reasonable cause. The IRS reviews the totality of facts in the written statement.

Taking the make-up distribution from physical metal

A self-directed IRA holding precious metals settles a make-up distribution the same way it settles a normal RMD, with one of two paths. The first is a cash distribution funded by a partial liquidation. The second is an in-kind distribution of physical metal at fair market value. Both produce a Form 1099-R from the custodian and both are taxable income for traditional IRAs.

The cash path runs through the dealer. The account holder instructs the custodian to sell a specified dollar amount of metal. The custodian coordinates with the dealer, who quotes a current bid price, executes the sale, and wires the proceeds back to the custodian. The custodian then distributes the cash to the account holder. The realized price depends on the dealer spread between bid and ask, which varies by product type. Augusta Precious Metals, Birch Gold Group, and Noble Gold Investments each publish a buyback policy that account holders can review before initiating the sale.

The in-kind path runs through the depository. The account holder instructs the custodian to ship physical metal valued at the required dollar amount based on the fair market value at the distribution date. The depository releases the specified ounces, coins, or bars to a designated address with insured carrier transit. The custodian reports the fair market value of the shipped metal as the distribution amount on Form 1099-R. The receiving account holder then holds the metal as personal property after the distribution.

A make-up distribution for a missed prior year is operationally the same as a current-year RMD. The arithmetic for the missed-year dollar amount uses the prior-year December 31 fair market value and the prior-year Uniform Lifetime Table factor. The current-year RMD continues to apply on its own normal schedule. Both flow through Form 1099-R but Form 5329 reports the missed year separately from the current year.

IRA aggregation and gold IRAs

The IRA aggregation rule for RMDs is described in IRS Publication 590-B. The RMD is calculated separately for each traditional IRA the account holder owns, then the total can be taken from any one or any combination of the IRAs. A gold IRA participates in the aggregate. A taxpayer with a $300,000 brokerage IRA and a $100,000 gold IRA calculates the RMD on each individually, sums the result, and may take the entire combined amount from the brokerage IRA only, from the gold IRA only, or from any split between them.

The aggregation flexibility is operationally useful when a gold IRA is part of the mix. A taxpayer who prefers to leave the physical metal undisturbed can take the full aggregated RMD from a cash-friendly brokerage IRA. A taxpayer who is comfortable liquidating or taking an in-kind shipment can satisfy part or all of the aggregate from the gold IRA. The choice is at the account holder level, not at the custodian level. The custodians do not coordinate the aggregation automatically.

Aggregation does not extend to employer plans. A 401(k), 403(b), or 457(b) calculates and distributes its RMD separately from any IRA aggregate (IRS RMD page). A missed RMD inside a 401(k) cannot be cured by an excess distribution from the gold IRA. The plans are separate calculations and separate excise tax exposures. The Roth aggregate is also separate for inherited Roth IRAs subject to RMDs.

Inputs your advisor will ask for

The conversation with a licensed tax advisor about a missed gold IRA RMD produces a faster and more substantive answer when the basic inputs are gathered ahead of time. The list below is not advice. It is the categories of information an advisor will typically need to model the situation.

With these six inputs, the advisor can decide whether to pursue the 10 percent correction, request a reasonable cause waiver, or accept the 25 percent rate, and can pick the operational source for the make-up distribution. The output is a plan calibrated to the specific tax position. We are not financial advisors. Consult a licensed advisor before making retirement decisions.

For readers who want to handle the valuation arithmetic themselves before the advisor meeting, the gold value calculator guide covers the spot-price-to-dollar conversion math. The authentication guide covers physical verification if an in-kind distribution is on the table. Both are operational tools, not investment recommendations.

Frequently asked questions

Sources and methodology

This guide describes federal rules under the Internal Revenue Code, IRS guidance, and the operational practices used by self-directed IRA custodians for precious metals accounts. Each factual claim links to a primary institutional source where available. State tax rules and plan-specific provisions may modify the federal rules described here.