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By Sarah Brenner, JD
IRA Analyst

Question:

I have been taking my RMDs on a monthly basis in 2020. Since the Cares Act has suspended RMDs for 2020, I would like to rollover my past 2 distributions. I would like to aggregate those two distributions and roll them over. I have not performed any rollovers within the last 12 months.

This is where it gets hairy. Some people are telling me I cannot aggregate the past two months distributions and roll them over as ONE rollover. However, those people who have taken their entire RMD as one lump sum vs. monthly are allowed to rollover the entire amount, which doesn’t seem fair.

Thoughts?

Thank you,

Rick

Answer:

Hi Rick,

We have been getting a lot of questions on this! You are running into the once-per-year rule. That rule says you can only roll over one distribution from an IRA back to an IRA in a 365-day period. That means that only one of your monthly RMD distributions can be rolled over. I can completely understand why that does not seem fair, but unfortunately that is how this rule works. You might consider rolling the second distribution into your workplace plan if you are eligible, or converting to a Roth IRA. Neither of these transactions would be subject to the once-per-year rule.

Question:

Dear Sir or Madam –

Two questions:

Inherited IRA Question –

I inherited a Traditional IRA at my mother’s death in 2005 and have been taking annual required distributions based on my life expectancy at that time.  My wife is named as my primary beneficiary of the Inherited IRA.

Question – At the time of my death, what are my wife’s options under the SECURE Act with regard to my inherited IRA?  Must she exhaust the inherited IRA within 10 years?

Roth IRA Question –

My wife is the Primary Beneficiary under my Roth IRA.  (Last year I rolled $20,000 from my Traditional IRA to the Roth which had been in existence for many years).

Question – At the time of my death, what are her options with regard to the Roth IRA under the SECURE  Act?  Can she roll it over to her own Roth or must she exhaust the Roth within 10 years?

Your response is sincerely appreciated and will be appreciated by my wife after I have passed away.

Bruce

Answer:

Hi Bruce,

You are correct about the first question. If an original IRA beneficiary of an inherited IRA dies in 2020 or later, the successor beneficiary (the beneficiary of the beneficiary) will be subject to the 10-year payout rule under the SECURE Act. This is true even if it is a spouse successor beneficiary.

As for your Roth IRA, your wife can do a spousal rollover. The Roth IRA will then become her own Roth IRA. She will not be subject to the 10-year rule because she is a spouse beneficiary.

https://www.irahelp.com/slottreport/cares-act-rmds-inherited-iras-and-ira-rollovers-todays-slott-report-mailbag