Returning 'RMDs' taken in Feb/Mar 2020 | Ed Slott and Company, LLC

Returning 'RMDs' taken in Feb/Mar 2020

It seems clear at this point that rolling over/returning what were thought to be RMDs taken in Jan 2020 are problematic, pending further clarification. What about a situation with distributions taken in Feb 2020 and in March 2020 (small distributions taken each month from 2 separate accounts). Clearly, the distributions taken in on month or the other can be rolled back in by 7/15/20, but can the aggregate of all 4 withdrawals be rolled over by 7/15/20? Or just those taken in one month or the other?

Starting with the Feb distributions, only one can be rolled back to a TIRA account. The only option for the others (3?) is to either convert them to a Roth by 7/15 or roll them into an accepting employer plan (for most plans only if still working there) by 7/15. Otherwise, they are taxable under the rollover rules. That said, if the taxpayer qualifies for a corona virus related distribution (CRD), they can all be rolled over to any eligible plan up to 3 years from the date of distribution. The IRS just broadened the CRD eligibility in Notice 2020-50, and they or Congress might not be through including January distributions, so keep tabs on developments.  In the meantime, you should roll over the one distribution permitted by 7/15.


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