2019 RMD in 2020, cares act?

Our client took his first RMD from 2019 in early 2020 before the cares act. We plan on skipping 2020 but can he roll back the 2019 RMD now?



  • The IRS released guidance a week ago that deadlines for time sensitive actions due >= 4/1 are postponed until 7/15. 4/1 was 60 days after 2/1.
  • That leaves only RMDs that occurred between 1/1 and 1/31 without the ability to rollover. There is a possibility that future IRS guidance or Congress will deal with this anomaly.

Where would someone obtain information if the  IRS issues further guidance on RMD(s) taken between 1/1 and 1/31?

The IRS would issue a Notice and any such notice would be widely published by the financial press. Or Congress may take this up in future relief legislation. This might also take the form of much broadened eligibility for corona virus distributions as that would also solve the rollover problem for January distributions.

Thank you for your response.

Agree. The CARES Act also waives 2019 RMDs if client reached 70.5 in 2019, but deferred their 2019 RMD (or a portion of it) to 2020. As spiritrider indicated, if client took any of their 2019 RMD on Feb 1 or later, they can roll it back up to 7/15. But they must have a rollover available under the one rollover limit.  And if they took the 2019 RMD in January, the same applies but will need further relief guidance from the IRS or Congress to do the rollover. However, if they end up quallfying for a corona virus related distribution which covers distributions back to 1/1, then they can roll any number of distributions back and have 3 years to do it without regard to the one rollover limit..

Thank you all, that is great to know! 

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