The CARES Act and RMDs: Today’s Slott Report Mailbag

Thursday, July 02, 2020

By Andy Ives, CFP®, AIF®
IRA Analyst
Follow Us on Twitter: @theslottreport

Question:

If someone took two IRA distributions earlier in 2020 that were considered RMDs, and now wishes to repay the cumulative amount back into the same IRA, are there any rules about the number of rollover deposits they can make in order to do so? Must it be done in 1 transaction, or 2, or could it be spread out across even more?

Thank you,

Adam

Answer:

Adam,

With IRS Notice 2020-51, released on June 21, the one-rollover-per-year rule and the 60-day rollover rule can both be bypassed for RMD payments that are returned by August 31, 2020. In your situation, one of the earlier RMD payments can go back as a rollover, and the other can be returned to the same IRA as a “repayment.” There is no limit on the number of “repayments” that can be done, as long as they are a return of RMD dollars and go back to the same IRA from which the RMD originated.

Question:

My custodian messed up my 2019 RMD (I’m in my 80s) and didn’t distribute it until January 10, 2020.  When I filed my 2019 taxes, I asked for a waiver of the 50% penalty on the missed 2019 RMD, armed with a letter from my custodian, and as expected, got it.  

Now it’s June 2020 and RMDs for 2020 are fully waived. Is my January 10, 2020 distribution (taken to fulfill my 2019 RMD) considered a RMD for 2020 and therefore waived and eligible for rollover?  

Also, a large part of the January 2020 distribution was for my 2019 withholding, which unfortunately went into 2020 rather than 2019.  ls there a way to reverse it or to apply 2020 tax payments to my 2019 taxes due July 15th?

Answer:

The CARES Act waived RMDs due in 2020. While it was taken in calendar year 2020, your distribution on January 10 was an RMD that was actually due in 2019. As an RMD due in 2019, it does not fall under the CARES Act waiver. As for the taxes withheld, since the distribution was actually taken in calendar year 2020, those dollars withheld will apply to 2020. Unfortunately, there is no way to reverse the withholding or to assign dollars withheld in 2020 to the previous year.

 

 

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