By Ian Berger, JD
I understand that I don’t have to take any RMDs during 2020. However, is the CARES Act rule that it is an-all-or-nothing for RMDs or can I take a portion of my RMD for 2020 but not all
Since RMDs are waived this year, you have complete flexibility. In 2020 you can take none of what would have been your RMD, some of it, all of it, or even an amount greater than what would have been your RMD amount.
Under the CARES Act, I understand that a beneficiary of an inherited IRA may not return/rollover any RMD already taken in 2020 back into the IRA. But what if the beneficiary just inherited the IRA in 2020? It is actually the decedent’s RMD that the beneficiary removed prior to enactment of the CARES Act. May the beneficiary roll the decedent’s RMD back in? I would appreciate your guidance on this.
Since RMDs are waived for 2020, the decedent did not have an RMD for this year. As such, there is no year-of-death RMD. But some RMDs were taken before the waiver was announced, which sounds like your situation. Immediately upon death, the account belongs to the beneficiary, and any distributions are the beneficiary’s, not the decedent’s. The beneficiary here is simply a victim of timing. Non-spouse beneficiaries may never do IRA rollovers, including “return” rollovers of subsequently-waived RMDs already taken in 2020.