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60-DAY ROLLOVERS: TODAY’S SLOTT REPORT MAILBAG

By Sarah Brenner, JD
IRA Analyst

Question:

Thank you for all the great resources you provide. I have been looking for an answer to my specific situation and have not been able to find a clear answer to what I think is a pretty straight forward situation/fact pattern.

I take my RMDs spread over a monthly basis on the 6th of each month. (I have taken four in 2020 – Jan, Feb, Mar, Apr). Under the new legislation that extends the “60-day rollover window” for distributions taken on or after February 1, 2020 to July 15, 2020, am I able to roll back all three distributions (Feb, Mar and Apr) in one contribution (rollover) into my IRA, or am I limited to only being able to roll back one month’s worth of distributions?

Thanks for your help and all you do.

Dale

Answer: 

This is a question that we have been getting frequently in the wake of the CARES Act waiving RMDs for 2020. Many individuals have their RMDs set up to come out of their IRAs monthly. Unfortunately, the once-per-year rollover rule will limit you to rolling over only one of these distributions from your IRA. The news is better if your RMDs are being distributed monthly from an employer plan. In that case, all the distributions could be rolled over because the once-per-year rule does not apply to plan-to-IRA rollovers.

Question:

Hello,

Our company currently subscribes to your publications. We had question we were hoping you could help us with.

If someone were to take a $10,000 IRA distribution on November 15, 2020 and then decided to use a 60 – day rollover and redeposit the funds in 2021, would they be able to reduce their 2021 RMD because the 2020 year-end balance would be lower by the $10,000?

Also, what would be the tax impact for 2020 and 2021? Would they need to still pick up the $10,000 income in 2020 even though it was re-contributed in 2021? It is our understanding that the 2020 1099-R would report the $10,000 as a taxable distribution.

We would appreciate any insight. Thanks again.

Best,

Nick

Answer:

There is no loophole here allowing for a reduced RMD for the next year if funds are not part of the December 31 IRA balance. While normally an RMD is calculated using the December 31 prior-year balance, the rules require that the balance be adjusted for an outstanding rollover. In other words, using your example, the $10,000 that was distributed in 2020 but rolled over in 2021 would need to be added to the December 31, 2020 balance used to calculate the 2021 RMD.

The $10,000 distribution would be reported on a 2020 Form 1099-R. It would not be taxable, however, because it was rolled over. This is true even though the rollover happened in 2021.

https://www.irahelp.com/slottreport/60-day-rollovers-todays-slott-report-mailbag

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