Potential 2020 RMD waiver in house and Senate relief bills.

Both bills include 2020 RMD waivers and the provisions indicate that distributions are eligible for rollover. What I don’t see is an exemption for the 60 day rollover period for January RMD distributions that are no longer RMDs. Following is the RMD waiver provision in the House Bill:

SEC. 403. TEMPORARY WAIVER OF REQUIRED MINIMUM DISTRIBUTION RULES FOR
CERTAIN RETIREMENT PLANS AND ACCOUNTS.

(a) In General.–Section 401(a)(9) of the Internal Revenue Code of
1986 is amended by adding at the end the following new subparagraph:
“(I) Temporary waiver of minimum required
distribution.–
“(i) In general.–The requirements of this
paragraph shall not apply for calendar year
2020 to–
“(I) a defined contribution plan
which is described in this subsection
or in section 403(a) or 403(b),
“(II) a defined contribution plan
which is an eligible deferred
compensation plan described in section
457(b) but only if such plan is
maintained by an employer described in
section 457(e)(1)(A), or
“(III) an individual retirement
plan.
“(ii) Special rule for required beginning
dates in 2020.–Clause (i) shall apply to any
distribution which is required to be made in
calendar year 2020 by reason of–
“(I) a required beginning date
occurring in such calendar year, and
“(II) such distribution not having
been made before January 1, 2020.
“(iii) Special rules regarding waiver
period.–For purposes of this paragraph–
“(I) the required beginning date
with respect to any individual shall be
determined without regard to this
subparagraph for purposes of applying
this paragraph for calendar years after
2020,
“(II) if clause (ii) of
subparagraph (B) applies, the 5-year
period described in such clause shall
be determined without regard to
calendar year 2020,
“(III) if clause (iii) of
subparagraph (E) applies, the 10-year
period described in such clause shall
be determined without regard to
calendar year 2020, and
“(IV) if clause (i) of
subparagraph (H) applies, the 10-year
period described in such clause shall
be determined without regard to
calendar year 2020.”.
(b) Eligible Rollover Distributions.–Section 402(c)(4) of the
Internal Revenue Code of 1986 is amended by striking “2009” each
place it appears in the last sentence and inserting “2020”.
(c) Effective Dates.–
(1) In general.–The amendments made by this section shall
apply for calendar years beginning after December 31, 2019.
(2) Provisions relating to plan or contract amendments.–
(A) In general.–If this paragraph applies to any
pension plan or contract amendment, such pension plan
or contract shall not fail to be treated as being
operated in accordance with the terms of the plan
during the period described in subparagraph (B)(ii)
solely because the plan operates in accordance with
this section.
(B) Amendments to which paragraph applies.–
(i) In general.–This paragraph shall apply
to any amendment to any pension plan or annuity
contract which–
(I) is made pursuant to the
amendments made by this section, and
(II) is made on or before the last
day of the first plan year beginning on
or after January 1, 2022.
In the case of a governmental plan, subclause
(II) shall be applied by substituting “2024”
for “2022”.
(ii) Conditions.–This paragraph shall not
apply to any amendment unless during the period
beginning on the effective date of the
amendment and ending on December 31, 2020, the
plan or contract is operated as if such plan or
contract amendment were in effect.