10-Year Rule for Year of Death 2020

Because the CARES Act eliminated the RMD requirement for 2020, did that “skip” 2020 for consideration of the 10-year rule, extending the final year for full distribution of the account to 2031? If yes, is there any guidance that validates this position?



No, the final year would be 2030 because the first year of a 5 year or 10 year rule does not count the year of death regardless of what the year of death was. The first year that counts is 2021. If a 2019 death fell under the 5 year rule, then 2020 would be skipped and 6 years would be allowed. 

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