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Natalie Choate & Denise Appleby on Notices 2020-50 and -51: New Guidance Expands Eligibility for CARES Act Non-RMD Rollovers and Coronavirus-Related Distributions: Clients Must Take Action by August 31, 2020, To Avoid Unnecessary Taxes!



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The Coronavirus Aid, Relief, and Economic Security (CARES) Act, include two significant financial relief provisions for retirement account owners and beneficiaries:

  1. Waiver of required minimum distributions (RMDs) for 2020 RMDs and permitted rollover of these amounts, and
  2. Penalty free coronavirus-related distributions (CRDs) by qualified individuals, of up to $100,000 per person.

By March 27, 2020 when the Act was signed into law, many account owners of RMD age and beneficiaries had already taken distributions that they though were RMDs- but were unable to use the CARES Act non-RMD rollover provision because of limitations under the Tax Code. In addition, it was unclear if taxpayers who were indirectly affected by COVID-19 qualified for CRDs.

The IRS recently issued guidance on the application of these provisions, which, in general, expanded eligibility to allow more taxpayers to benefit. This guidance is provided under:

  • Notice 2020–51: Guidance on Waiver of 2020 Required Minimum Distributions, and
  • Notice 2020–50: Guidance for Coronavirus-Related Distributions and Loans from Retirement Plans Under the CARES Act.

Both of these include some welcome surprises that every practitioner who advises clients about these provisions should know.

Join Natalie Choate and Denise Appleby as they explain the key provisions covered in these two Notices, and how you can use them to help your clients. Topics that will be covered include:

  • The August 31 deadline for rollovers of certain RMDs
  • How the IRS permits rollovers of RMDs that were otherwise never permitted—but ONLY if completed by August 31, 2020!
  • How to identify clients who may still qualify for rollovers beyond August 31, 2020, through the CRD provision
  • Possible solutions for non-RMD/non-CRD amounts
  • Who is eligible for a CRD?
  • The tax benefits of a CRD
  • Rollover rules for CRDs


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