The recently passed legislation mentions “shall not apply for calendar year 2020…” Is this a mistake that is going to result in those turning 72 in 2020 with an RBD of April 1, 2021 actually having an RMD for tax year 2020 while those with a December 31, 2020 deadline to complete their RMD spared from having to take the RMD?
No IRA owner could have an RBD in 2021 due to the Secure Act. In this case, the individual reached 70.5 before 2020, so the RBD would be 4/1/2020. Under CARES, both the 2019 and 2020 RMDs would be waived, except to the extent of the 2019 RMD that was distributed in 2019.
Ah, good point. Anyone reaching age 72 in 2020 will have already reached their RBD on April 1, 2019 or April 1, 2020 and the new subparagraph 401(a)(9)(I) indicates that the RBD continues to be determined as it was without the CARES Act.
Alan, To be clear. Are you saying that if someone was waiting until April 1, 2020 to take their 2019 RMD, they are now not required to take that 2019 RMD? Thanks; as always.
Permalink Submitted by David Mertz on Fri, 2020-03-27 21:17
No. Those with an RBD of April 1, 2021 will not have to take a 2020 RMD. This section of the tax code is virtually identical to the section of the tax code enacted to waive 2009 RMDs (except for changing “2009” to “2020” and changes to accommodate the new 10-year rule) and 2009 Pub 590 explicitly indicates that 2009 RMDs were waived for those who had an RBD of April 1, 2010.