2020 IRA RMD to Roth Conversion | Ed Slott and Company, LLC

2020 IRA RMD to Roth Conversion

I have a client that took their RMD in January of 2020. With Notice 2020-51, he can now put that genie back in the bottle. My question is can he roll the cash directly into his ROTH IRA? Or does it have to go through a two-step process of rolling the funds back into the IRA and then do the ROTH Conversion as a separate transaction?

If an IRA distributed this RMD he can only roll the amount back to the distributing IRA account by the 8/31 deadline. He cannot use cash unless cash was distributed in January. Meanwhile he can convert any amount he wishes from the TIRA now since the conversion is not related to the rollover of the RMD back to the TIRA. 


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