Reversing IRA distributions by 11/30/09

Are you able to rollover any amount you withdrew from your IRA in 2009, by November 30th, even if it was greater or less than your RMD?



No.
The first distribution of 2009 is deemed to be the RMD, first overdo RMDs from prior years and second the 2009 RMD. For the 2009 RMD, any amount up to but not exceeding that 2009 RMD amount may be rolled over up to 11/30. If the RMD came out in more than one payment, only one distribution can be rolled over within 12 months in order not to violate the one rollover limitation, so care must be taken to be sure there have not been other rollovers from the distributing account in the prior 12 months.



The extension until 11/30/09 will lead to lots of confusion, I’m afraid.

First, if someone took a distribution in 2009 and they’re the owner (not a beneficiary) of the account, they can roll it back within 60 days – assuming they haven’t violated the 1 per year rule. If they took a say $15,000 in January and the RMD would be only $7,000 – they can roll back the $7,000 but the $8,000 cannot be rolled back. If it is, it’s an excess contribution, subject to the 6% penalty. If they RMD is $7,200 and they’re having $600 per month transferred their taxable account, they can only roll back $600 or they’d violate the one per year rule.

If someone took an RMD September 15 as a beneficiary from an inherited IRA, they cannot roll it back at all.

I wish everyone will do this correctly but I’m afraid there will be errors.



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