RMD and IRA Contributions



Will there be any relief for those who took a RMD before the CARES ACT?Alos, can an individual make an IRA contribution for the tax year 12/31/19 if they are over 70 1/@ 



  • The IRS has released relief for those actions due 4/1 or later, which includes rollovers of Feb distributions. However, still no relief for those who took their 2020 RMD in January since those rollovers were due before April 1st. That allowed them no time to complete a rollover after RMDs were waived in March.
  • For those age 70.5, the first year a TIRA contribution is allowed is 2020. If someone reached 70.5 in 2019, they cannot make a 2019 TIRA contribution, but can for 2020.


  • Yes, I see it now in Notice 2020-23.  I was looking for an explicit reference to rollovers or for a reference to February 1 rather than to April 1.  It just so happens that the 60th day prior to April 1 was February 1:
  • “The Secretary of the Treasury has also determined that any person performing a time-sensitive action listed in either § 301.7508A-1(c)(1)(iv) – (vi) of the Procedure and Administration Regulations or Revenue Procedure 2018-58, 2018-50 IRB 990 (December 10, 2018), which is due to be performed on or after April 1, 2020, and before July 15, 2020 (Specified Time-Sensitive Action), is an Affected Taxpayer.”


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