Your need to take a 2020 RMD is waived
Earlier this year the CARES Act was signed into law. One of the benefits of this Act was the elimination for the requirement to take a Required Minimum Distribution (RMD) for 2020 from most retirement plans, including Inherited IRA’s. This waiver does not, however, apply to defined benefit plans.
72t Distributions are the exception
Accounts taking substantially equal periodic payments (sometimes called a 72t) are not allowed to miss their 2020 RMD distribution. If you are taking these “72t” payments, and the 2020 RMD is not taken, all previous distributions will be subject to the 10% penalty.
What if you already took your RMD?
Many people had already taken their RMD before the ACT was passed into law. In Notice 2020-51 , the IRS is allowing someone who has already taken their 2020 RMD to put it back into their retirement account. This is permitted even if the 60-day window period has lapsed. If you have already done a 60-day Rollover in the past 12 months you normally could not do another one, but with the new rule you have until August 31st, 2020 to put the funds back in the account. The funds must be returned to the account they came from.
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