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Internal Service Revenue Notice 2020-51 – Updated Guidance Regarding Retirement Plans

June 24, 2020


Treasury issued Notice 2020-51 today on CARES Act § 2203, the 2020 Waiver of Required Minimum Distributions (“RMDs”) that contained important (and in part some surprising) guidance.  Here are some of these important points.

  • All distributions in 2020 from a Plan or IRA that were 2020 RMDs can be rolled over or put back into the Plan or IRA so long as that is completed by August 31, 2020.
  • The ability to put the funds back into an IRA includes the ability of a beneficiary of an inherited IRA to return to the inherited IRA the funds distributed to the beneficiary as a 2020 RMD.
  • A distribution in 2020 that is part of a series of substantially equal periodic payments may also be rolled over, although the plan participant can’t cease those payments in 2020 without penalty.
  • The one rollover per 12 month limitation does not apply to 2020
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