Required minimum distribution and Cares Act

Submitted by Arun SHAH on Mon, 2020-06-01 16:05

I have taken minimum distribution for 2020 form my employer plan only in the 2nd week of January 2020 and they also withhold federal tax. I was retired in 2019 and took minimum distribution in 2019
Can I still rollover money back to my employer plan based on Cares Act before July 15th 2020?

Thanks,

Arun R Shah

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Permalink Submitted by William Tuttle on Mon, 2020-06-01 17:29

Not unless you meet the qualifications for a Coronavirus Distribution (CVD) under the CARES Act.

You, your spouse or your dependents have tested positive for the SARS-CoV-2 virus.
You and only you have experienced adverse financial consequences as a result being

quarantined,
furloughed or laid off or having work hours reduced
unable to work due to lack of child care
closing or reducing hours of a business owned or operated by the individual

Otherwise, only distributions on or after 2/1/2020 have until 07/15/2020 to do an indirect rollover.

Permalink Submitted by Arun SHAH on Tue, 2020-06-02 14:16

As per section 2203 (III) (ii) (II) such distribution not having made before January 1, 2020.

Permalink Submitted by William Tuttle on Tue, 2020-06-02 16:09

If you do not meet the CVD qualifications listed above, you are left with 60-day rollover rules.
IRS notice 2020-23 only allows time sensitive actions due 04/01/2020 or later to be postponed until 07/15. This means only distributions on or after 02/01/2020 are eligible to be postponed until 07/15/2020.
As I pointed out in my previous post if you took a distribution in January 2001. The 60-day period has long expired and you are not eligible for the postponment until 07/15/2020.
You should really use the search function. This question has been asked and answered several times. As repeated stated by Alan S, you are out of luck unless the IRS issues further guidance or Congress passes legislation to that effect. I have not heard or any such provision.

Permalink Submitted by Arun SHAH on Tue, 2020-06-02 18:03

As per Sentor reply based on I may be able to do it if it is from 401k.SEC. 2203. 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 DATESIN 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, and ‘‘(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.’’. (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.