CARES Act – Potential Changes

I have read there might be some expansion/relaxation to the 60-day rollover window for those who took IRA or employer plan distribution earlier this year and are no longer eligible for a 60 day rollover. First, is this true? Second, what is the best way to follow any proposed changes?



  • There are probably too many proposals to be worth following, but you could pull up proposed Congressional legislation. However, the IRS has considerable authority to make regulations interpreting the CARES Act, and will have to act fast. You might therefore check the IRS website to see the official regulation or release. Apparently, there are many aspects of the CARES Act that will need a technical corrections bill fairly fast. When passed that will be on the Congressional legislation site. 
  • It appears that CV distributions will be taxpayer reported on Form 8915 B (basically the honor system). This form has been used for natural disaster distributions in the past, and already addresses, reporting distributions over 3 years, penalty waiver, roll backs, 100k limit, etc. Once all 2020 distributions  can be treated as CV distributions, the 60 day rollover deadline becomes 3 years and none of the rollovers count against the one per 12 month limit. 
  • Another place to find a very quick explanation of approved changes in very understandable verbiage is MIchael Kitces “Nerds Eye View” blog. For example, the following was released the same day the Act was signed.
  • https://www.kitces.com/blog/analyzing-the-cares-act-from-rebate-checks-to-small-business-relief-for-the-coronavirus-pandemic/?utm_source=Nerd%E2%80%99s+Eye+View+%7C+Kitces.com&utm_campaign=4b3655b1e2-NEV_MAILCHIMP_LIST&utm_medium=email&utm_term=0_4c81298299-4b3655b1e2-57212157

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