2020 RMD Rollover

Good Morning, My client took his 2020 rmd in early january total 30K. Now under the cares act and the ability to rollover the dollars back into his IRA he is wondering if he has to do the full amount or can he do just a portion, say half? Thank you.



  • With a January distribution, the only way client can roll it back is qualifying for a corona virus distribution which means testing positive or spouse testing positive for the virus or suffering financial consequences defined as not being able to work because of the virus. If totally retired, he will not qualify unless the IRS guidance broadens the definition. 
  • Rev Procedure 2016-47 is a remote possibility also, but client must qualify for one of the “reasons” for such a delayed rollover. Link to this procedure next:
  • https://www.irs.gov/pub/irs-drop/rp-16-47.pdf


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