Deadline to return a Covid Distribution or Loan

Hello, can we confirm what the deadline is to return a distribution or loan hat was taken for Covid-19 reasons. Is it three years from the day after the distribution was taken or the have up until 12/31/2023 to return the funds?

Thank you.



The deadline is 3 years starting on the day after the CRD was received. 

Does the “same property rule” for rollovers apply to CRD repayments? If a client distributed cash for the CRD, does the repayment need to be made in cash? Or can in-kind shares be returned to replace the cash CRD? Thank you. 

Repayments of CRDs are treated as rollovers but without the 60-day limitation, so the repayment must be in cash.  Even if it was permitted, depositing shares in-kind would make no sense because any cost basis in the shares would be lost.

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