Every month, IRA expert Ed Slott is taking your questions about Individual Retirement Accounts on AARP:
The CARES Act suspended RMDs for 2020, but I already took my RMD. Can I now return it and eliminate the tax bill?
Maybe. The CARES Act waived RMDs for 2020, but some people had already taken them and now want to know if they can be returned. By “returned” they are referring to rolling the funds back to an IRA or company plan, which would eliminate the tax bill, as if the RMD never happened. So, the first step is to see if the funds are eligible to be rolled over.
Normally, RMDs cannot be rolled over or returned to an IRA or plan. But since the CARES Act waived RMDs due in 2020, the RMD you took is no longer classified as an RMD, so it can be rolled over, but only if it meets these tests: