dmertz
Level 15

Retirement tax questions

These would qualify as Coronavirus-Related Distributions only if you met the requirements for being an affected individual.  See SECTION 1.B of IRS Notice 2020-50 for those requirements.

 

Regarding the February distribution, the rollover deadline for that distribution has not yet expired.  The IRS extended the rollover deadline to July 15, 2020 for distributions made after January 31, 2020 that will have the regular 60-day deadline expire before July 15 (actually due to the federal disaster declaration by the President, not the CARES Act).  So you can roll that distribution over without that distribution being a CRD.

 

However, the January distribution is another matter.  Unless you qualify as an individual described in SECTION 1.B of IRS Notice 2020-50 sot that the January distribution can be treated as a CRD, the January distribution cannot be rolled over.  There is nothing in the specific wording of SEC. 2202 of the CARES Act that actually requires that the distribution be made after you became a qualified individual.