Updated RMD Requirements

I had a client that turned 70.5 in December of 2019. She has a small 403b account with an employer that she no longer works for. Does she need to take an RMD from that account for 2019? Or does it fall under the 2020 provision where RMDs were suspended?

If she does need to take and RMD, does the requirement for taking an RMD by April 1st of the year after 70.5 get pushed back because tax filing dates were pushed back?

Thank you for all your help!



The CARES Act includes a waiver of 2020 RMDs, but also if the taxpayer reached age 70.5 in 2019 and has not taken their 2019 RMD in that year, the 2019 RMD that would have been due in early 2020 is also waived. Therefore, the client will have their first TWO RMDs waived. If client wants to do a direct rollover to an IRA, she should make sure the 403b plan understands this, but even if the plan distributed amounts to her (as RMDs), they really are not RMDs and she could roll them over to her IRA within 60 days.

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