The early-distribution penalty is eliminated only on early-distributions that qualify as coronavirus-related distributions. Distributions that do not qualify are still subject to the early-distribution penalty unless one of the permanent exceptions applies:
(A) CORONAVIRUS-RELATED DISTRIBUTION.—Except as provided in paragraph (2), the term “coronavirus-related distribution” means any distribution from an eligible retirement plan made—
(i) on or after January 1, 2020, and before December 31, 2020,
(ii) to an individual—
(I) who is diagnosed with the virus SARS–CoV–2 or with coronavirus disease 2019 (COVID–19) by a test approved by the Centers for Disease Control and Prevention,
(II) whose spouse or dependent (as defined in section 152 of the Internal Revenue Code of 1986) is diagnosed with such virus or disease by such a test, or
(III) who experiences adverse financial consequences as a result of being quarantined, being furloughed or laid off or having work hours reduced due to such virus or disease, being unable to work due to lack of child care due to such virus or disease, closing or reducing hours of a business owned or operated by the individual due to such virus or disease, or other factors as determined by the Secretary of the Treasury (or the Secretary's delegate).
Similar to Forms 8915-A and 8915-B for qualified disaster distributions, the IRS will certainly need to introduce a new form for optionally spreading the income of a coronavirus-related distribution equally over the 2020 through 2022 tax years.
