CARES Act | Ed Slott and Company, LLC

CARES Act

The language in the act, which provides a waiver of RMD's for 2020 appears to only apply to those who have a Required Beginning Date of 4/1/2020 and opted to not take some or all of their RMD during the calendar year 2019. This is a very narrow subset of people taking RMD's. It may also apply to an inherited IRA, with the first RMD in 2020. the Act doesn't appear to apply to anyone else who is currently subject to RMD's in 2020. Am i missing something? Thanks

The RMD waiver applies to 2020 RMDs, and to 2019 RMDs with an RBD of 4/1/2020 to the extent the 2019 RMD was deferred to 2020. Therefore, a small group will have 2 years of RMDs waived. Inherited IRAs do not have RBDs as such, so inherited IRA RMD waivers only apply to 2020 RMDs. If the 5 year rule applies for deaths prior to 2020, an additional year is added to the 5 years effectively making for a 6 year rule.

 

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