If you are subject to the Minimum Required Distribution Rule [*1], the CARES Act grants you the right to skip this year's distribution. All well and good, if that is what you want to do.
But, what if you have already taken the distribution?
CARES also grants you an option. Specifically, RMDs paid out in 2020 can be rolled over to another IRA, another qualified retirement plan, or returned to the original plan by Aug. 31, to avoid paying taxes on that distribution. The waiver applies to RMDs received from traditional IRAs, SEP IRAs, SIMPLE IRAs, 401(k) plans, 403(b) plans, 457(b) plans, profit sharing plans and other defined contribution plans. The waiver does not apply to qualified defined benefit plans.
Conveniently, CARES suspends the "one rollover per year" limitation too. That means you can take advantage of this opportunity - and still have wiggle room to restructure your retirement portfolio if you need to.
Please note: The deadline to take this action is about a week away. There has not been any discussion of extending the date, that we have heard. (In fact, IRS sent a reminder note to practitioners just this morning!)
One thing is totally absent from Notice 2020-51: Any discussion of whether you should skip this year's RMD at all (or roll it over if you have already taken it). For that discussion, Take a look at our website article RMD Relief and Early Plan Withdrawals-Loans. (Visit our Library-Archive Page to find out what else we have been thinking about lately).
[*1] If you are over 72 years old at the end of 2020, or you were 70 1/2 or older at any time during 2019, you are required to make actuarial determined withdrawals from your traditional IRAs, SEP IRAs, SIMPLE IRAs, 401(k) plans, 403(b) plans, 457(b) plans, profit sharing plans and other defined contribution plans. (The rule does not apply to ROTH accounts unless you inherited them.) Failure to make the distribution or to make it in sufficient amounts is one of the more expensive ways to use your retirement funds. If you face this penalty, it can often be abated - if you act soon enough. Give us a call if you need help: Steven@StevenRoyManagement.Com or  489-4228.