2019 RMD – can this be returned due to Covid?

Submitted by Roselyn Siino on Thu, 2020-04-23 16:38

A client would like to undo or return his 2019 RMD because it will increase his tax liability and impact Medicare. Is there any loophole with Covid that will allow an individual to return all or part of an RMD from 2019 (past the 60 days) to the IRA. Can someone claim a hardship to allow for that? Any advice here?



Submitted by Alan - IRA critic on Thu, 2020-04-23 17:53

  • If the client turned 70.5 last year and if the 2019 RMD was postponed to 2020, that RMD could be rolled back as if it was a 2020 RMD. However, that distribution had to be taken after January and the client could not have already used up their one permitted rollover. Any RMD actually distributed in 2019 cannot be rolled back.
  • If client met the technical requirements of a CRD, any distribution taken in 2020 can be rolled back for up to 3 years. But most people do not meet those requirements at this time. IRS guidance could loosen the requirements however. 


Submitted by Roselyn Siino on Fri, 2020-04-24 15:23

Thanks for the reply! To be clear, CRD is “coronavirus related distribution” right?  Are CRDs only applicable in situations where the IRA owner is under 59 1/2? This would not apply here if the IRA owner is 74 right? It sounds like this 74 year old does not have any way to undo the 2019 RMD since it was taken way past the 60 days and will need to deal with the increased Medicare and tax liability despite the new landscape with Covid, right? Unless some other legislation comes out…? 



Submitted by Alan - IRA critic on Fri, 2020-04-24 15:54

Yes, CRDs are corona virus distributions and are allowed without age consideration if the person qualifies. However, this 2019 RMD still will not qualify because it was not taken in 2020 unless it was late, and if late it will not be eligible for rollover because it’s still an RMD because it is for 2019. The chance of additional legislation that would include 2019 RMDs is extremely slim since 2019 was completed prior to the crisis. As mentioned before, there was an exception for those who turned 70.5 in 2019, but this also does not apply to this client.



Submitted by Roselyn Siino on Fri, 2020-04-24 16:24

Very helpful, thank you Alan-Iracritic!



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