There’s been a flurry of recent government regulation of company retirement plans. Here’s a quick summary:Electronic Disclosure of Retirement Plan DocumentsOn May 27, 2020, the Department of Labor published a final regulation making it easier for employers to issue retirement plan notices to participants electronically. Notices can be posted on a website or mobile app or delivered via email. Employees who prefer hard copies can opt out of electronic delivery and receive paper disclosures instead.
Question:If someone took two IRA distributions earlier in 2020 that were considered RMDs, and now wishes to repay the cumulative amount back into the same IRA, are there any rules about the number of rollover deposits they can make in order to do so? Must it be done in 1 transaction, or 2, or could it be spread out across even more?Thank you,AdamAnswer:Adam,With IRS Notice 2020-51, released on June 21, the one-rollover-per-year rule and the 60-day rollover rule can both be bypassed for RMD payments that are returned by August 31, 2020.
IRAs are supposed to be for saving for retirement but in challenging economic times like these many individuals may be forced to take distributions before retirement age. Be careful! If you tap your IRA before reaching age 59 ½, the bad news is that you run the risk of being hit with the 10% early distribution penalty. The good news is that there are some exceptions to this penalty. You IRA distribution will still most likely be fully taxable, but you can spare yourself the additional 10% penalty if one of these exceptions apply to you.
After a six-month sprint through a diabolical obstacle course of new laws, a pandemic, record unemployment, deaths, confusion and complete disruption of everyone’s professional and personal lives, this seems like a good time to recap the madness of the pr
Question:Hi Ed,If a person takes that 100k distribution, can they elect to split evenly in 2020-2022 as income? Or can they determine how to apply the income?ShannonAnswer:Hi Shannon,Those persons who qualify for up to $100,000 of 2020 coronavirus-related distribution (not everyone does) can spread out income evenly over their 2020-2022 tax returns.
The IRS has extended the rollover deadline for required minimum distributions (RMDs) taken from IRAs or company plans in 2020. In Notice 2020-51, released on June 23, the IRS said that any unwanted 2020 RMDs can be repaid via rollover to an IRA or company plan by August 31, 2020.Normally, RMDs cannot be rolled over. However, the CARES Act waived 2020 RMDs (and first-time 2019 RMDs delayed until 2020) from IRAs and defined contribution plans. For this reason, amounts received in 2020 that would have been RMDs are eligible for rollover since they are technically not RMDs.
Are you acting in your clients’ best interest when it comes to rollovers? On June 30, the new SEC Regulation Best Interest (Reg BI) becomes effective. Reg BI establishes a “best interest” standard of conduct for broker-dealers when they make recommendations to clients of any securities transaction or investment strategy involving securities. Reg BI specifically covers proposals for rolling over funds from a workplace retirement plan account to an IRA.Under the new standard, brokers must “exercise reasonable diligence, care and skill when making a recommendation to the client.” This requires the financial professional to understand the risks and rewards of the recommendation, as well as its costs, for each client.
On June 19, the IRS released additional guidance on coronavirus-related distributions (CRDs) from retirement accounts. The new guidance will make many more individuals eligible for these tax-advantaged distributions allowed under the CARES Act.What Is a CRD?If you qualify as an “affected individual”, you can take up to $100,000 of distributions from your IRAs and employer plans in 2020. There is no 10% early distribution penalty if you are under age 59 ½, and you have an option to spread the federal tax on CRDs evenly over a three-year period beginning with the year 2020. You also have a three-year period to repay CRDs to an IRA or employer plan. Taxes can be refunded on the amounts repaid. Repayment does not have to be made to the same IRA or company plan from which the CRD was originally paid.
Question:Thank you for all the great resources you provide. I have been looking for an answer to my specific situation and have not been able to find a clear answer to what I think is a pretty straight forward situation/fact pattern.I take my RMDs spread over a monthly basis on the 6th of each month. (I have taken four in 2020 - Jan, Feb, Mar, Apr). Under the new legislation that extends the "60-day rollover window" for distributions taken on or after February 1, 2020 to July 15, 2020, am I able to roll back all three distributions (Feb, Mar and Apr) in one contribution (rollover) into my IRA, or am I limited to only being able to roll back one month's worth of distributions?Thanks for your help and all you do.Dale
FIX: Rolling Over the Tax Withheld on a Distribution. Was the mandatory tax of 20% withheld on your work plan withdrawal even though you intended to roll over the entire account? Did you change your mind on an IRA withdrawal and now want to roll it back, but you elected to have taxes withheld on the initial distribution? If money was withheld for taxes on a distribution from a work plan or an IRA and you want to roll over the distribution plus taxes withheld, you can make up the difference “out-of-pocket.” The money withheld and sent to the IRS is gone, but you can replace that withholding with other dollars, roll over the full amount, and have a credit waiting for you for the amount withheld when you do your taxes next year.
