By Ian Berger, JD
The virus pandemic has prompted legislation that has eliminated the requirement for me to take a required minimum distribution (RMD) from my IRA for the year 2020. Am I therefore allowed to do a partial Roth IRA conversion in 2020 without having to take 2020 RMD first?
Yes. The CARES Act RMD waiver for 2020 means you are not required to receive your RMD before doing a Roth IRA conversion in 2020 – or at any time. The same rule applies to any 2020 IRA rollover for anyone who would normally have an RMD due.
I took my 2020 RMD in full about 6 weeks ago. I’m wondering if the RMD waiver for 2020 can be applied retroactively, allowing me to roll back or otherwise undo this unfortunate distribution. My 60-day rollout clock (if it applies) is ticking!
We have gotten this question a lot!
Because of the CARES Act RMD waiver, the RMD you already received was not technically an RMD. This means the RMD can be rolled over as long as two conditions are met. The first is that the rollover must occur within 60 days of the day you received the RMD. The second is that you must not have received another distribution during the 12 months prior to receipt of the RMD that you rolled over the same way as the rollover you wish to do (traditional IRA-to-traditional IRA or Roth IRA-to-Roth IRA). If both of these conditions are met, you should be able to do the rollover.