As part of the CARES Act, Congress waived the Required Minimum Distribution (RDM) requirements for 2020. Under existing law, taxpayers have 60 days from the date of distribution to roll back the RMD into the plan. The timing of the law change meant that taxpayers who took distributions in January had already exceeded the 60 day rollover period and were not able to put the money back into their plan.
IRS issued Notice 2020-51 on June 23rd 2020 modifying the 60 day rollover rule. Taxpayers can now rollover distributions until the later of 60 days from the date of distribution or August 31, 2020. This change allows taxpayer who took RMDs in January to roll back the RMD by August 31st.
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.
