dmertz
Level 15

Retirement tax questions

You are correct.  If you have not suffered financially from the pandemic, you do not qualify for a CRD unless you are actually diagnosed with the infection.  If you don't qualify, you cannot treat your February distribution as a CRD.  Since the distribution is not a RMD, your only option to do a rollover is to complete the rollover by July 15, 2020.

 

Notice 2020-23 permits the rollover-deadline extension by reference to IRS Revenue Procedure 2018-58 (https://www.irs.gov/pub/irs-drop/rp-18-58.pdf) which explicitly lists time-sensitive acts for which the deadline has been extended (postponed).  Included in that list is #23 of Section 8, the deadline for rolling over an IRA distribution.