Post age 70 IRA contribution

Hi – I just want to make sure I am correct with the post-SECURE Act changes and timing here. Client is 71.5 and unless congress were to pass the proposed legislation increasing RBD age for RMDs will certainly be on the hook for an RMD here in 2022 as 72nd bday is September. That RMD is around $6000. Client is slated to take two withdrawals to satisfy the RMD and more by taking $3600 both in July and August.

Client is also still working and while doesn’t make a lot of money, will have earned income for 2022 in excess of $10,000.

Can the client:

1. do a rollover of $1200 back to her IRA that is above and beyond her RMD within 60 days of receipt of the 2nd distribution (Note: I am aware of the 1 r/o per year rule)

and

2. also make a contribution (to the extent cash flow allows) of the full $7000 for 2022?



  1. Yes, but client is then locked out of another such rollover for 12 months. I assume there is some reason that the August distribution cannot be reduced by 1200 to eliminate the need for a rollover.
  2. The new contribution can be made, but if it is deducted the next QCD (if any) will have to be reduced by the amount of the deduction. 


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