CARES Act and 60-day rollover in last 12 months
What if I did a 60-day rollover in December 15th of 2019, then took what I expected to be an RMD on February 15 of 2020. Under standard rules logic tells me I couldn’t do a 60-rollover because I’m still in the 12 month window. However, if I have the distribution qualify as a CVD then I could pay this back any time in 2020 regardless of the 12 month 60-day rollover window, correct? My understanding is that returning distributions back to an IRA per the CARES Act will be done as an unlimited number of allowable 60-day rollovers for up to three years. This way, returning the assets will not impact contribution limits. Please confirm or correct my understanding. Thank you.
Permalink Submitted by Alan - IRA critic on Fri, 2020-04-03 22:41
That is correct. You should probably wait until the IRS releases more guidance on this situation and until the custodians have been provided coding instructions to accept CV related rollovers. It is expected that you will be able to do this, but unless you have been directly impacted per the CARES Act specific occurrences, you should wait awhile until this situation is cleared up.