TaxGuyBill
Level 15

@Terry53029 wrote:

@TaxGuyBill Mike said his client paid back a distribution. It is not a rollover and should be reported as I described earlier.

The notice 2020-51 is not only information for rollovers. This is from that notice, and the part that would apply to Mike's client.

 D. Permitted repayments of RMDs previously distributed from an IRA. In the case of
an IRA owner or beneficiary who has already received a distribution of an amount that
would have been an RMD in 2020 but for section 2203 of the CARES Act or section 114
of the SECURE Act, the recipient may repay the distribution to the distributing IRA, even
if the repayment is made more than 60 days after the distribution, provided the
repayment is made no later than August 31, 2020. The repayment will be treated as a
rollover for purposes of § 408(d)(3) of the Code, but will not be treated as a rollover for
purposes of the one rollover per 12-month period limitation in § 408(d)(3)(B) and the
restriction on rollovers for nonspousal beneficiaries in § 408(d)(3)(C). 


 

As your citation points out, it *IS* treated as a rollover.

 

It is NOT a "Qualified Disaster Distribution".   See Form 8915-E and its instructions for what a "Qualified Disaster Distribution" means.

https://www.irs.gov/pub/irs-pdf/i8915e.pdf

 

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