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No.  If you have a non-qualified withdrawal from a Roth IRA, it is subject to income tax plus a 10% penalty.  The CARES act lifts the 10% penalty but not the income tax.

 

You can withdraw your original taxed contributions tax free at any time, even without the CARES act.  But if you withdraw earnings, that is subject to the rules about qualified and non-qualified withdrawals.  A non-qualified withdrawal is a withdrawal that is made if you are under age 59-1/2, or if the Roth IRA has been open less than 5 years even if you are over 59-1/2.   Under the ordering rules for Roth IRAs, it is assumed that any money you withdraw first comes from contributions, then from rollovers and conversions, and lastly from earnings. 

 

IF you have more than $50,000 of contributions, you can withdraw that without tax or penalty and you don't need the CARES act.  If that withdrawal exceeds your original contributions and starts cutting into your earnings growth, that part which is earnings will be subject to regular income tax, but not the penalty if you file under the CARES act.

 

The tax form will likely just have a check box to claim the withdrawal under the CARES act.  We don't know what proof the IRS might ask for during audits and compliance review. 

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