12 Months Rule

If a client wants to do an IRA Withdrawal and put his money back within 60 days but did this recently. Does the 12 months rule apply from the date he took his last distribution or the deposit of the last rollover?



Does the $100k rul rollover count against the 12 month rule? 

The 12 months starts from the date of the distribution that was rolled over, not from the date of the rollover contribution.  Not sure what the 100k refers to, but if you are referring to a QCD paid to a charity, this is just a distribution, not a rollover, even though it is reported on Form 1040 similar to a rollover.

This is what I am referring to with the 100k rule: A coronavirus-related distribution is a distribution that is made from an eligible retirement plan to a qualified individual from January 1, 2020, to December 30, 2020, up to an aggregate limit of $100,000 from all plans and IRAs.

OK – A repayment of a CRD, which can occur up to 3 years from the date of distribution and can occur with multiple repayments, is not treated as a rollover subject to the one rollover limitation.  Therefore, CRDs can be ignored for this rule, but they also must be properly reported on Form 8915 E as well as repayments, so the IRS knows that a distribution is a CRD or not.

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