I have encountered a fact pattern that I have not previously come across. All help and guidance is greatly appreciated
T-IRA owner, 72, has 2 IRAs
IRA #1 holds mutual funds
IRA #2 holds a VA (income rider has been activated)
Owner satisfies RMDs (from each IRA) via monthly installment payments
Earlier this year client took 2 distributions (in addition to monthly installment payments) in the amounts of $10K & $50k respectively - totaling $60k - funds were earmarked to help pay for a home for his child, however the purchase fell through.
**Client's RMD was only partially satisfied at the time of the 2 distributions - however the 2nd distribution of 50k more than satisfied 2019 RMD
Client subsequently rolled over (repaid) the first distribution in the amount of $10,000 within 60 days
Is it possible to rollover (via 60 day) 2nd distribution of $50k minus the amount ($15k) that satisfied the RMD - In other words can $35,000 be rolled over? Or does the first distribution/rollover of $10k count as his once-per-12 months rollover?
Was the $10,000 roller allowed? My reason is "no" because at the time he hadn't satisfied his RMDs RMDs can't be rolled over. Assuming my logic is sound - how is that corrected?
$10,000 distribution taken on 4/23 and repaid (rolled over) 6/21
$50,000 distribution taken on 6/13