T-IRA RMD + 60 day rollover | Ed Slott and Company, LLC

# T-IRA RMD + 60 day rollover

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

Questions(s)
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?

Note:

\$10,000 distribution taken on 4/23 and repaid (rolled over) 6/21
\$50,000 distribution taken on 6/13

### With the exception of the

• With the exception of the date of the \$50,000 distribution, this appears to be the same client as in this question:  https://www.irahelp.com/forum-post/43356-12-month-ira-rollover
• To answer your specific questions, the \$10,000 rollover was permitted because it's a rollover of part of the \$50,000 distribution, not the \$10,000 distribution.  Any part of the \$50,000 that is not RMD is eligible for rollover.  (The \$10,000 distribution is apparently all RMD and not eligible for rollover.)