401k and 457 RMDs CARES Rollover?

Hello,

Client took two separate RMDs, one from their 401k and another from their 457, the sum total was $70k. Can they roll the entire $70k into their IRA as part of the CARES 60-day rollover expansion? Or would rolling the two separate withdrawals violate the one rollover per calendar 12 rule?

Thank you,

Bob



There is no one rollover limitation for distributions from a non IRA plan, and these distributions are not treated as RMDs.  If these distributions were made on 2/1 or later they can both be rolled over to an IRA by 7/15/2020, as the 60 day time limit was extended for such distributions.

Hi Alan, Thank you as always. Understood on the no one rollover limit from plan-to-IRA. Just to confirm, when you say “these distributions are not treated as RMDs”, that only applies to 2020 because of the CARES Act, correct? In any other year those would be considered RMDs?

That is correct. CARES only eliminates RMDs for 2020. For a year with RMDs, the first distributions are treated as RMDs and cannot be rolled over.

Thank you Alan.

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