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Education
Any colleges expenses paid in the same calendar year, as the 529 distribution, are qualified, whether paid directly with the funds or not.
What's not clear is whether your situation applies. Your distribution was in 2019 but the expenses will not be paid until 2020.
The IRS has not, to my knowledge, yet published any guidance on how covid 529 refunds will be handled. I suspect they'll be lenient, given the circumstances. You are effectively meeting the intent of the rules.
It is clear that the 60 day rule for refunds does apply. Even though it's a hassle, re-contributing the money may be the safe move.
Reference: https://www.savingforcollege.com/article/can-i-recontribute-a-refund-to-my-529-plan
‎April 24, 2020
7:29 AM