Aggregated RMDs
I believe it was in this forum that I read that a rollover under the CARES Act rules would require the IRA owner to return the money to the IRA that it came from. Assuming that to be the case, my client may have a dilemma. He aggregated his RMDs for two IRAs, taking one distribution for both IRAs from just one IRA. If he can only return the RMD amount, AND if he must return the RMD to the IRA that it came from, is he stuck?
Permalink Submitted by Alan - IRA critic on Wed, 2020-07-01 19:15
Only rollovers of IRA Distributions allowed by 8/31 under the recent Notice 2020-51 must be rolled to the distributing IRA. Prior guidance (such as rollbacks of distributions from 2/1 on with a 7/15 deadline allowed the rollover to be made to any eligible account. But your client does not have a problem, since he can return the total RMD to the account that distributed it, even though some of that RMD was generated by another account under the aggregation rules. There is one distributing account here, and the amount distributed is treated as an RMD, so can be rolled back to the distributing account.