In Notice 2023-54, 2023-31 I.R.B. ____ (7/31/2023), the Internal Revenue Service has provided some guidance on transition rules for both the changes made by the SECURE 2.0 Act of 2022 (Division T of the Consolidated Appropriations Act of 2023, P.L. 117-328) and the regulations that were proposed at 87 F.R. 10504 (2/24/2022) for the “SECURE Act” (Setting Every Community Up for Retirement Enhancement Act of 2019, P.L. 116-94).

The notice covers the following issues:

• When they are final, the proposed regulations will not apply to years before 2024.
• Relief is provided for distributions made in 2023 that were believed to be RMDs but were not RMDs because of changes made by the SECURE 2.0 Act and so eligible for rollover treatment.
• Some failures to make required minimum distributions in 2023 will not be subject to excise taxes or other consequences.

Practitioners who may have clients interested in or affected by these issues should review the notice.