2020 Rollover Limits

Are rollovers under updated CARES act changes allowed for all distributions made in 2020 or only up to the amount of the RMD taken but no longer wanted? For example, client RMD for 2020 is $4000. Client takes out $5000. Can all $5000 be returned or is the client capped at the $4000 RMD level.

Thanks.



Under Notice 2020-51, only amounts up to the RMD can be rolled back under the rules contained in that Notice. Other amounts can be rolled back, but only subject to the prior rules containing certain time limits and where subject to the one rollover limit, if applicable.

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