On March 27, 2020, the President signed the Coronavirus Aid, Relief, and Economic Security Act, also known as the CARES Act. Section 2203 of the CARES Act waives the required minimum distribution (RMD) rules for tax year 2020, including 2019 RMDs for individuals that attained age 70½ in 2019 which were due to be distributed between January 1, 2020 and April 1, 2020. Since then, additional guidance provided by the Internal Revenue Service (IRS) gives IRA owners and beneficiaries the opportunity to repay to an IRA amounts that under normal circumstances would have been an RMD for 2020, allowing these individuals to avoid paying tax on the distribution.
IRS Notice expands rollover relief
The IRS released Notice 2020-51 on June 23, 2020 which provides additional guidance on the repayment of waived 2020 RMD amounts. The Notice further extends the deadline to return RMD amounts and expands availability:
- The repayment of waived RMD amounts to an IRA is treated as a rollover contribution
- Waived RMD amounts distributed and received from January 1, 2020 through July 2, 2020 may be rolled over on or before August 31, 2020
- Waived RMD amounts received after July 2, 2020 must be rolled over within 60-days of receipt
- Unlimited number of separately distributed waived RMD amounts can be rolled over (i.e., the distributions are not subject to the one-per year rollover rule)
- The RMD waiver and repayment rules apply to death distributions made to a spouse or nonspouse beneficiary
The five-year rule
The 2020 RMD waiver also affects beneficiaries that inherited an IRA prior to 2020 and elected the five-year rule. Under the five-year rule a beneficiary IRA generally must be closed by the end of the fifth year following the IRA owner’s death. The CARES Act extends the five-year period, which is determined without regard to 2020.
Zane inherited an IRA in 2018 and elected to take distributions using the five-year rule. Under normal circumstances Zane would need to deplete the IRA by December 31, 2023, the end of the fifth year following the IRA owner’s death. However, the 2020 RMD waiver rules allow Zane to ‘skip’ 2020, providing him with an additional year to take distributions from the inherited IRA, and making the deadline to deplete the IRA December 31, 2024.
IRA owner notification
Notice 2020-51, Q&A 11 states that an IRA custodian/trustee must notify IRA owners that no RMD is due for 2020. One method of informing an IRA owner that there is not an RMD requirement for 2020 is by properly completing the 2019 Form 5498, IRA Contribution Information, and furnishing a copy to the IRA owner. Box 11 of Form 5498 is titled ‘Check if RMD for 2020’ and contains a check box. Notification to an IRA owner will be satisfied by not checking Box 11 on the 2019 5498.
The guidance provided in Notice 2020-51, has improved the usefulness of the 2020 RMD waiver rules in the CARES Act. Allowing amounts that under normal circumstances would have been considered RMD amounts in 2020 to be rolled over; allowing the repayment of multiple distributions of waived RMD amounts received during 2020 to be rolled over; extending the deadline from July 15, 2020 to August 31, 2020 to roll over waived RMD amounts distributed and received from January 1, 2020 through July 2, 2020; and providing nonspouse beneficiaries the ability to roll over waived RMD amounts are all significant modifications to the rules.
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