IRS Notice 2020-51 issued on June 23, 2020 now allows until August 31, 2020 for one to "repay" a distribution made from an IRA in 2020 that would have been an RMD were it not for Section 2203(a) of the CARES Act. This includes repayments by non-spouse beneficiaries. The amount that can be repaid under this notice is limited to the amount that would otherwise have been required to have been distributed as an RMD. Such a repayment also is disregarded with respect to the one-rollover-per-12-months rule.
(Apparently by terming it a "repayment" and limiting it to amounts that would otherwise be an RMD, it avoids limitations that would otherwise apply to rollovers, effectively a return of a mistaken distribution.)
