Cares act

RMDS are waived for 2019 and 2020. If a client makes a ROTH conversion in 2020 would they have to take an RMD too? Keith. Email eval(unescape(‘%64%6f%63%75%6d%65%6e%74%2e%77%72%69%74%65%28%27%3c%61%20%68%72%65%66%3d%22%6d%61%69%6c%74%6f%3a%4b%74%6f%75%73%61%69%6e%74%40%69%6e%76%65%73%74%6d%65%6e%74%63%74%72%2e%63%6f%6d%22%3e%4b%74%6f%75%73%61%69%6e%74%40%69%6e%76%65%73%74%6d%65%6e%74%63%74%72%2e%63%6f%6d%3c%2f%61%3e%27%29%3b’))



2019 RMDs are only waived if the IRA owner reached 70.5 in 2019 and deferred the 2019 RMD into early 2020. Otherwise, the 2019 RMD is due and the first distribution taken in 2020 is deemed to apply to the 2019 RMD remaining and cannot be converted. When did client reach 70.5? If prior to 2019, while the 2019 RMD is not waived, a 2020 conversion can be done before making up the late 2019 RMD because there are no 2020 RMDs. 



The client and owner is 74 and had taken 2019 RMDs. Seeks to waive 2020 RMDs and convert Traditional IRA assets into a ROTH IRA. 



Pretty simple then. He can do the conversion anytime he wishes and in any amount that he is willing to pay taxes on. Put another way, he should treat 2020 as if this were a year before his RMDs ever started, before he reached 70.5.



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