The CARES Act and 2019 RMDs deferred to 2020
Does the CARES ACT in any way affect a 2019 RMD that was deferred to 2020?
The 2019 RMD was distributed before April 1, 2020 instead of in 2019.
Does the CARES Act allow this RMD to be rolled back over into the IRA….as is the case with 2020 RMDs that were taken this year?
Thanks,
Permalink Submitted by Alan - IRA critic on Thu, 2020-08-27 18:18
Yes, when the RBD is 4/1/2020, the deferred 2019 RMD is waived and if it was distributed can be rolled back to the distributing IRA account. However, the deadline to complete this rollover is 8/31, so it may be too late unless the custodian will accept the rollover using postmark rules, or by hand delivery.
Permalink Submitted by Robert Gibb on Thu, 2020-08-27 21:02
I assume that if someone deferred their 2019 RMD to 2020 and have not yet taken the deferred RMD this year, then they are fine and do not have to take the 2019 deferred RMD this year.Would they ever have to take the 2019 deferred RMD….would they need to take it next year (2021)?
Permalink Submitted by Alan - IRA critic on Thu, 2020-08-27 21:19
In this situation, both the portion of the 2019 RMD deferred to 2020 AND the 2020 RMD are waived. Whenever an RMD is waived (or rolled back per Notice 2020-51 or otherwise) the account is not depleted by the amount that would have been an RMD and therefore the year end balance in all future years will be marginally higher than it would have been and all your future RMDs will be larger as a result. Therefore, in a sense that waived RMD will gradually translate into the taxes still being collected eventually, just later than they would have been. That is why many are converting what would have been RMDs deferred from 2019 or 2020. This is done in a lower income year and depletes the TIRA like the RMD would have. Therefore, future RMDs will not be larger than they would have been.