When the Coronavirus Aid, Relief and Economic Security (CARES) Act was passed, it provided relief from unwanted required minimum distributions (RMDs), and the accompanying tax burden, for many Americans by waiving some RMD requirements for 2020. This provided immediate tax relief and allowed some investors to keep their money invested.

Unfortunately, since the CARES Act wasn’t signed into law until March 27, 2020, many people had already taken RMDs. As retirees began looking for ways to “put back” those 2020 distributions via indirect rollover, they found they were subject to the normal 60-day rollover period and once-per-year rollover rules. This meant that many distributions taken before February 1 were already past the 60-day window.

In March, the IRS issued Notice 2020-23, which extended any time-sensitive filing deadlines due on or after April 1, 2020 to July 15, 2020. This gave investors until July 15, 2020 to put back one distribution taken after February 1, 2020. Individuals who took distributions in January were still out of luck.

However, in late June, the IRS issued Notice 2020-51 that addressed some holes in the CARES Act, including:

• January 2020 distributions were not eligible to be put back
• Only one RMD distribution could be put back, so individuals that take their RMDs over multiple distributions could only put back one
• While inherited RMDs were waived for 2020, any distributions already taken could not be put back

The following distributions are now eligible to be put back under Notice 2020-51:

1. Any RMDs taken in 2020–including those taken in January 2020
2. Multiple RMD distributions; now, you have the opportunity to put back all distributions that went towards your required minimum
3. RMDs from inherited qualified accounts which must be repaid back to the same inherited IRA
4. RMDs from retirement plans (401(k)s, IRAs, etc.)
5. 2019 RMDs that were deferred into 2020

Individuals have until August 31, 2020 to put back their RMDs. Distributions that exceed RMD amounts, and those taken by individuals under age 72, are not eligible for the broad relief and are instead subject to the normal 60-day rollover and once-per-year rollover rules. Work with your financial advisor and tax professional to ensure you meet the requirements before putting back any distributions.

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.