06/25/2020
2020 IRA ROLLOVER OPPORTUNITY
Section 2203(a) of the CARES Act provides for a waiver of required minimum distributions (RMD’s) for defined contribution plans and IRA’s for 2020. This waiver also applies to the 2019 RMD for an individual who has a required beginning date of April 1, 2020, that was not paid in 2019 (and therefore would have been due to be paid between January 1, 2020 and April 1, 2020).
The Treasury Department and the IRS have recently announced relief to allow taxpayers who receive certain distributions to roll them into an eligible retirement plan. Specifically, distributions to a plan participant that are paid in 2020 (or paid in 2021 for the 2020 calendar year) that equal the amounts that would have been RMD’s in 2020 (or for 2020), but for section 2203 of the CARES Act (2020 RMD’s) may be rolled over, provided the other rules of § 402(c) are satisfied (and regardless of whether the distributions would otherwise be made as part of a series of substantially equal periodic payments).
To assist plan participants who have already received distributions in 2020, the Treasury Department and the IRS, are extending the 60-day rollover period for any payments described above so that the deadline for rolling over such a payment will not be before August 31, 2020. For example, if a participant received a single-sum distribution in January 2020, part of which was treated as ineligible for rollover because it was considered an RMD, that participant will have until August 31, 2020, to roll over that part of the distribution. In addition, the Treasury Department and the IRS, are extending the 60-day rollover period for IRA distributions in 2020 that would have been an RMD in 2020 but for section 2203 of the CARES Act or section 114 of the SECURE Act, so that the deadline for rolling over such distributions will not be before August 31, 2020.
The bottom line is if you have taken a 2020 distribution from an IRA or defined contribution plan it is likely eligible for rollover until August 31, 2020. If completed such a rollover will avoid the taxation of such distribution in 2020 and provide additional tax deferred growth.
If you have received such distributions and wish to complete a rollover you should speak to your financial and income tax advisors as soon as possible to comply with the August 31, 2020, deadline.