Congress passed the CARES Act in March 2020 which provides individuals with IRA, 401(k), and other employer sponsored retirement accounts, the option to waive their required minimum distribution (RMD) for the 2020 tax year. This option is available to both individual over the age of 70½ and non-spouse beneficiaries of inherited IRA’s. In this article we will review:
- The new RMD waiver rules
- RMD’s for individuals age 70.5
- RMD’s for beneficiaries of Inherited IRA’s
- What happens if you already took your distribution for 2020?
- Options for putting the RMD back into your IRA
Who Qualifies For The RMD Waiver?
Unlike other provisions in the CARES Act that require an individual to demonstrate that they have been impacted by the Coronavirus to gain access, the waiver of 2020 required minimum distributions is available to everyone. If you were age 70½ prior to December 31, 2019 or are the non-spouse beneficiary of an IRA, you are typically required to take a small distribution from your IRA each year, called an “RMD”, and pay tax on those distributions. However, for 2020, if you want to keep that money in your IRA in 2020 and avoid the tax hit associated with taking the distribution, you have the option to do so.
What If You Already Took Your RMD for 2020?
If you already received the RMD amount from your IRA for 2020, you may be able to return it to your IRA, and avoid the tax hit.
If the distribution came from your own personal IRA, not an inherited IRA, you will have two options:
OPTION 1: If the distribution happened within the last 60 days, you can simply return the money to your IRA. For this option, you are utilizing the 60-day rollover rule which allows you to take money out of an IRA, return it within 60 days, and avoid the tax liability. You are only allowed one 60-day rollover every 12 months.
OPTION 2: If the distribution took place more than 60 days ago, you will only be allowed to return it to your IRA if you qualify based on one of the four Coronavirus-Related Distribution criteria:
- You, your spouse, or a dependent was diagnosed with the COVID-19
- You are unable to work due to lack of childcare resulting from COVID-19
- You own a business that has closed or is operating under reduced hours due to COVID-19
- You have experienced adverse financial consequences as a result of being quarantined, furloughed, laid off, or having work hours reduced because of COVID-19
If you qualify under one of these items, then you will have 3-years from the date of the distribution to return the money back to your IRA and avoid the tax hit. However, while you have 3-years to return it to the IRA, if you don’t return the money to your IRA prior to December 31, 2020, you will have a tax liability in 2020 for all or a portion of that IRA distribution. It’s only when you actually return the money to your IRA that the tax liability is nullified. If you return it in a future tax year, you would have to go back and amend your 2020 tax return to recapture the taxes that were paid.
Inherited IRA – Non-spouse Beneficiary
However, if you are a non-spouse beneficiary of an IRA, the rules for returning the money to your IRA are different. If you are a non-spouse beneficiary of an IRA and you already received your RMD for 2020, you cannot return that money to your IRA to avoid the tax liability. Why is this? Beneficiaries are not eligible to make rollovers, so that disqualifies them from return the money to the IRA under the rollover rules in the CARES Act.
A Note To Our Greenbush Financial Clients
If you wish to waiver your RMD to 2020 or if have already received your RMD, and wish to process a rollover back into your IRA, 401(k), or employer sponsored plan, please contact us.
Hi, I’m Michael Ruger. I’m the managing partner of Greenbush Financial Group and the creator of the nationally recognized Money Smart Board blog . I created the blog because there are a lot of events in life that require important financial decisions. The goal is to help our readers avoid big financial missteps, discover financial solutions that they were not aware of, and to optimize their financial future.