Yes, in this case the CARES Act also provides relief. Specifically, if a participant turned 70½ in 2019 and has a Required Beginning Date of April 1, 2020:
- If the participant has not yet taken the distribution—then no distribution is required in 2020 (for the 2019 RMD year).
- If the participant took the distribution after December 31, 2019, then it is subject to the RMD waiver for 2020 and the amount can be redeposited as a rollover within 60 days of receipt. Additional IRS guidance may be needed if the 60-day period has passed and the participant still wants relief.
- If the participant took the distribution in 2019, then the waiver doesn’t apply to the 2019 RMD.
Notice 2020-23, published by the IRS on April 9, appears to provide limited relief with respect to the 60-day window for taxpayers who:
- Took an RMD between February 1 and May 15, 2020, AND
- Didn’t complete another indirect rollover in a 365-day period preceding the date these funds are redeposited, AND
- Redeposit the funds to a retirement plan or IRA by July 15, 2020.
NOTE: The option to redeposit funds is not available to RMDs withdrawn from inherited IRAs because money from inherited accounts is not allowed to be rolled over under the Internal Revenue Code. No relief has been provided for withdrawals from retirement accounts taken from January 1 to January 31.