The CARES Act provides those who qualify for a CRD to take up to 100k in distributions from their IRA (or employer plans) up to 12/30/2020. This is reported on Form 8915E with your 2020 return, and on that form you elect whether to pay all the taxes in 2020, or report 1/3 of the CRD each year 2020-2022. If the taxpayer is married, each spouse can distribute up to 100k, but only from their respective IRA accounts. All or part of the CRDs can be repaid to an IRA over a period up to 3 years from the date of each respective CRD. Repayments are also reported on Form 8915, and a repayment made up to the due date plus extensions for each tax return will first offset taxable income for that year, and then for either a future or past year at the election of the taxpayer. Therefore if taxpayer distributes 100k and elects to report 1/3 of the income each year (election also does not become final until the due date for respective return, and repays 20k by 4/15/2021, the taxable CRD income for 2020 will be 13,333  (33,333 less 20,000 repaid by due date). However, if repayment is made toward the end of the 3 year period, taxpayer will have to amend the prior years to claim their refund. Repayments are treated as direct transfers, so there is no concern with the one rollover limitation. An IRA custodian must be told of repayments so they code them properly on Form 5498 and to avoid reporting as a rollover contribution. FIrst, be sure the taxpayer qualifies for a CRD. See Notice 2020-50.

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