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CARES Act RMDs, Inherited IRAs and IRA Rollovers: Today’s Slott Report Mailbag

Question: I have been taking my RMDs on a monthly basis in 2020. Since the Cares Act has suspended RMDs for 2020, I would like to rollover my past 2 distributions. I would like to aggregate those two distributions and roll them over. I have not performed any rollovers within the last 12 months. This is where it gets hairy. Some people are telling me I cannot aggregate the past two months distributions and roll them over as ONE rollover. However, those people who have taken their entire RMD as one lump sum vs. monthly are allowed to rollover the entire amount, which doesn't seem fair.
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IRS Issues Q&As on Coronavirus-Related Distributions

Under the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), certain individuals can take up to $100,000 of distributions from IRAs and company plans during 2020 and receive special tax relief. Those distributions are known as coronavirus-related distributions (CRDs). On May 4, the IRS released a set of Q&As pertaining to CRDs. The IRS did not address many of the questions about CRDs left unanswered in the CARES Act itself. However, the IRS did promise additional guidance “in the near future.”
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THE MEGA BACKDOOR ROTH IS USUALLY TOO GOOD TO BE TRUE

For a number of years, the “mega backdoor Roth” strategy has been touted as a way for employees to convert large amounts of after-tax employee contributions to Roth IRAs. Unfortunately, in most cases the strategy won’t work. Here’s why. First, a little background. The mega backdoor Roth is simply the company retirement plan version of the backdoor Roth IRA. The backdoor Roth IRA is designed for individuals whose income exceeds the IRS limit for making Roth IRA contributions directly. The backdoor strategy allows for higher income employees to make Roth contributions indirectly by making a traditional IRA contribution and subsequently converting it to a Roth IRA.
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IRA Contributions and RMD Withdrawals Under the CARES Act: Today’s Slott Report Mailbag

Question: Dear Mr. Slott, I seem to have gotten myself into a jam with my 2020 RMD withdrawal and the CARES Act, as it stands now. Hoping you are able to help, or make a suggestion on how to proceed. In January, over three withdrawals, I took my entire 2020 RMD from an IRA. Then the CARES Act seemed to forgive/not require distributions during 2020. I returned the money to my IRA. Now the law has made a determination that RMD withdrawals beginning February 1, 2020 through May 15, 2020 and placed back into IRA accounts are forgiven. Well, my January RMD withdrawal was not forgiven, but I had already placed it back into the IRA account.
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