qbteachmt
Level 15

"The literature does not specifically state COVID19 as a reason but I plan on using it."

The reference you pointed to has the provision for Disaster declaration. Now you follow the CARES ACT for what it included, which includes RMD waiver, and Rollover Treatment for them that is specifically more than the 60-day limit and avoids the "one per 12 month" restriction, as well.

In fact, If you took distribution, you would have 3 years to repay it and have it treated as a rollover.

An RMD would be redeposited by Aug 31 to be treated as ignored.

All of that is in the CARES provisions.

https://www.investopedia.com/how-the-coronavirus-stimulus-bills-affect-you-4800404

"Special Rules for Retirement Funds (Phase 3)

(3) The CARES Act effectively waives the 10% tax penalty for early withdrawals from retirement funds if those withdrawals are related to the coronavirus. The waiver is retroactive to Jan. 1, 2020. In addition, those who withdraw from retirement funds have up to three years to either pay the income tax due on the withdrawal (normally due the same year) or redeposit the funds withdrawn with no tax penalty. IRS guidance expanded eligibility for IRA, 401(k) withdrawals up to $100,000 for people who started a job late, had a job offer rescinded, or were spouses with retirement accounts affected by COVID-19, in addition to those directly affected by the coronavirus.22

 

Also, account owners subject to required minimum distributions (RMDs) from their retirement accounts do not have to take RMDs in 2020 to allow time for the funds to build up again.8"

And the IRS has lots of specific notifications, as these things got passed the notifications were issued:

https://www.irs.gov/newsroom/coronavirus-relief-for-retirement-plans-and-iras

 

The disaster distribution eligibility is right in the Form 8915-E instructions:

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

 

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