By Andy Ives, CFP®, AIF®
As we have written on many occasions, the “Coronavirus Aid, Relief, and Economic Security Act” (CARES Act) waives required minimum distributions (RMDs) for 2020. This waiver applies to company savings plans and IRAs, including both inherited traditional and inherited Roth IRAs. While that sounds like a straightforward announcement, the RMD waiver has generated a landslide of inquiries and confusion since the CARES Act was passed in late March. Here are a dozen of the most popular and widely applicable Yes/No questions and answers:
1. My RMD is sent to me automatically on a monthly schedule. Even though I already took a portion of my 2020 RMD, can I stop the remaining monthly payments? YES
2. My 75-year-old father passed away in January without taking his 2020 RMD. Now my siblings and I are establishing inherited IRAs. Do we need to take his year-of-death RMD? NO
3. Can I still take my 2020 RMD if I want to? YES
4. Since RMDs are waived for 2020, if I decide to take it anyway, does that mean there is no tax due on that withdrawal? NO
5. If I received multiple 2020 RMD payments, can I roll them all back to my IRA? YES (as long as they are all returned by August 31, 2020).
6. I have an inherited IRA and already took my RMD. Can I roll it back/replace it? YES (as long as the inherited RMD is repaid to the same IRA by August 31, 2020).
7. Will I need to take both my 2020 and my 2021 RMD next year? NO
8. Since RMDs are waived, can I do a Roth conversion without taking my RMD first? YES
9. I turned 70½ last year and my first RMD was for 2019, but my required beginning date was April 1, 2020. I delayed taking this first RMD until 2020. Is that RMD waived under the CARES Act? YES
10. Can I now roll my 401(k) into an IRA without taking the 2020 RMD? YES
11. Can I still do a qualified charitable distribution (QCD) even though my RMD is waived? YES (as long as you are otherwise eligible).
12. Do I need to be an “affected person” under the coronavirus rules for the RMD waiver to apply to me? NO