WSJ on returning RMDs per Notice 2020-51 | Ed Slott and Company, LLC

WSJ on returning RMDs per Notice 2020-51

In the WSJ June 24 article regarding returning RMDs per Notice 2020-51, the following two statements appeared in succession:

If you inherited a 401(k) or IRA and took an RMD this year, you can return the money, Mr. Slott said. Normally, nonspouse beneficiaries "can never put an RMD back," but the IRS made an exception for them this year, said Mr. Slott.

When returning an RMD, you can deposit the money in the account it came from or in another tax-deferred account.

My question is about the second statement above, about returning an RMD. Can I take my 2020 RMD distributed at the beginning of February from my 403b plan and deposit it before 8/31 into my IRA of a different custodian? If not, what is the correct interpretation of the second WSJ statement above which says "you can deposit the money ... in another tax-deferred account"?

Thanks again for your help.

  • Yes, what would have been an RMD from your 403(b) were it not for section 2203 of the CARES Act can be rolled over to your IRA by August 31, 2020.
  • If the distribution was instead from an IRA, Notice 2020-51 indicates that it must be repaid to the IRA from which it was distributed.  (The WSJ statement is a bit too broad with respect to distributions from IRAs.)

Thanks for the quick response.  Just to make sure I understand Notice 2020-51, let me restate what I think you've said since I have both a 403b plan and an IRA from which RMDs must be taken.  If my 2020 RMD came from my IRA, it will have to go back to the distributing IRA.  If my 2020 RMD came from my 403b plan, it may be put back to my IRA.  Did I get the distinctions correct?

Yes, that's the way I read III.C and III.D of Notice 2020-51, respectively.

So another variation would be to take partial 2020 RMD from a 401k and then return 50%  to an IRA by Aug 31, 2020.  Is that permitted?

The amount of the 401(k) distribution permitted to be rolled over by August 31, 2020 can be any amount up to the amount that would have been the RMD for the 401(k) were it not for the CARES Act.  There is no requirement that the entire distribution be rolled over.  Partial indirect rollovers of rollover-eligible distributions have always been permitted.

Appreciate and thank you for the prompt response!When the partial indirect rollover funds are deposited into the IRA, does the IRS require filing any forms? Perhaps a 5498?

The taxpayer must report both the full distribution and the remaining taxable amount in the event of a partial rollover directly on Form 1040, as usual for rollovers. There is no other form. The IRA custodian will issue Form 5498 showing the rollover contribution to an IRA. The IRS will then computer match the 1099R with the 5498 in the process of checking the tax return. This is the same process as a full rollover.


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