Reply To: IRS broadens rollover relief for 2020 RMDs

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#8354
Alan S.
Participant

OK, now your concern makes more sense. You did make a distribution that went into your personal bank account, and therefore must report it on a 1099R, code 7 (normal Dist). However, unless you need to file a 5500 EZ (or 5500 SF) for another reason, you do not need to file the form due to rolling back the “would have been” RMD to the plan. The 5500 EZ instructions request reporting rollovers from OTHER plans, but this is not a rollover from another plan, it is just a return of the amount of the would be RMD from your personal checking account. And there is no other form needed to report the return of the would be RMD to your plan.

However, you will need to report the distribution and rollback on your 1040 (lines 4c and 4d) to prevent the 1099R from becoming taxable. As noted earlier, the IRS Notices do not allow a plan trustee to avoid the issuing a 1099R if a non loan distribution is made.