Instructions for 5329 state "Prior tax years. If you are filing Form 5329 for a prior year, you must use the prior year's version of the form. If you do not have any other changes and have not previously filed a federal income tax return for the prior year, file the prior year's version of Form 5329 by itself (discussed earlier). If you have other changes, file Form 5329 for the prior year with Form 1040X, Amended U.S. Individual Income Tax Return."
Seems to miss situation where prior year federal income tax return HAS been filed but there are no other changes.
Client summed balances across all IRAs and a 401(k) and took a single first-year distribution in 2015 only from an IRA. Should have taken an RMD from the 401(k). In 2016 took the required 2015 and 2016 distribution from the 401(k).
Needs to file 5329 with statement on corrective action taken and request to waive 50% penalty.
Should this be on standalone 5329?
Seems to miss situation where prior year federal income tax return HAS been filed but there are no other changes.
Client summed balances across all IRAs and a 401(k) and took a single first-year distribution in 2015 only from an IRA. Should have taken an RMD from the 401(k). In 2016 took the required 2015 and 2016 distribution from the 401(k).
Needs to file 5329 with statement on corrective action taken and request to waive 50% penalty.
Should this be on standalone 5329?