Notice 2020-23 and CARES Act
I understand the clarification provided in Notice 2020-23 allows for RMDs taken as far back as 2/1/20 to be rolled back by 7/15/20. Does this too extend the 60-day window for a Roth conversion opportunity by 7/15/20 for 2020 RMD already taken? In other words, if I took an RMD on 2/1/20, do I have the option to choose between rolling back to the IRA/employer plan or rolling back to a Roth IRA as a Roth Conversion by 7/15/20?
Permalink Submitted by Alan - IRA critic on Tue, 2020-04-14 14:24
Yes, you could do the conversion until 7/15. In fact, you might have to if you took automatic distributions on 2/1 and 3/1 since you can only roll one of those back under the one rollover per 12 month limit. But since a conversion does not count as a rollover for those purposes, you could not roll the second distribution back to a TIRA, so your choice is either to keep the distribution or convert it.