Were you on the ball and already took your required minimum distribution (RMD) early?
As many now know, as a result of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, RMDs were waived for 2020 for all retirement accounts, including inherited accounts. That’s great, but if you had known about the waiver at the beginning of the year, you may not have taken your distribution.
So, is there a way to somehow reverse this RMD? The IRS has finally issued some guidance:
The Internal Revenue Service announced that anyone who already took a required minimum distribution (RMD) in 2020 from certain retirement accounts now has the opportunity to roll those funds back into a retirement account following the CARES Act RMD waiver for 2020.
The 60-day rollover period for any RMDs already taken this year has been extended to August 31, 2020, to give taxpayers time to take advantage of this opportunity.
The CARES Act enabled any taxpayer with an RMD due in 2020 from a defined-contribution retirement plan, including a 401(k) or 403(b) plan, or an IRA, to skip those RMDs this year. This includes anyone who turned age 70½ in 2019 and would have had to take the first RMD by April 1, 2020. This waiver does not apply to defined-benefit plans.
In addition to the rollover opportunity, an IRA owner or beneficiary who has already received a distribution from an IRA of an amount that would have been an RMD in 2020 can repay the distribution to the IRA by August 31, 2020. The notice provides that this repayment is not subject to the one rollover per 12-month period limitation and the restriction on rollovers for inherited IRAs.
It’s important to note that if you took RMDs from multiple accounts and you wish to put all or some of these back, you will be allowed to do so, as these will not be subject to the once-per-12-month rollover limitations.
Additionally, while no clear guidance has been provided by the IRS, experts like Jeffrey Levine, Director of Advisor Education at Kitces.com, states: Finally, while beneficiaries are explicitly prohibited from completing 60-day rollovers under the law, Notice 2020-51 essentially allows beneficiaries to temporarily ignore this portion of the Internal Revenue Code and rollover their 2020 inherited ‘RMDs’ until as late as 8/31/2020. This is an important difference, since previous communications had excluded beneficiary retirement accounts from this ability to rollover RMDs.
As with many things this year, there are new details and changes to guidance almost weekly, so we will do our best to keep you informed, but certainly call our office if you or your friends and family have questions on RMDs or any of the other myriad of pandemic-related policy.
This information is not intended to be a substitute for specific individualized tax or legal advice. We suggest that you discuss your specific situation with a qualified tax or legal advisor.