Under IRS Notice 2020-51 Reminder: August 31 is the final day a taxpayer may roll over an RMD taken on or after January 1, 2020 back into an IRA. The notice also clarifies that the one rollover per 12 month period limitation does not apply to 2020 RMDs that are recontributed to a retirement accounts by August 31, 2020.
The CARES Act provides that taxpayers with an RMD requirement due in 2020 may skip those RMDs in 2020. The 2020 RMD suspension also includes anyone who turned age 70½ in 2019 and would have had to take their first RMD by April 1, 2020. The 2020 RMD suspension does not apply to defined benefit plans.
Eligible retirement accounts are:
- Defined contribution plans (IRC §403(a) and (b));
- Tax-sheltered annuity plans (IRC §403(b));
- Defined contribution plans under IRC §457(b) maintained by a state or municipal government (the waiver does not apply to current or former employees of exempt organizations that maintain an IRC §457(b) plan); and
- An individual retirement plan such as a traditional, SEP, or SIMPLE IRA.