The CARES act applies to all 2020, even though it was not enacted until March. If you missed a 2019 RMD, then you are subject to the usual rules, even though it might have been COVID-related.
The answer below was posted in a different thread by one of the Turbotax experts. I will add that if you missed a 2019 RMD because of illness in December 2019, you can probably use your illness as "reasonable error" for 2019 in your letter of explanation, but your "reasonable steps to remedy the error" will probably mean that you have to withdraw your 2019 RMD amount now, even though you can waive the 2020 RMD.
@DawnC wrote:
Not unless this is your very 1st required minimum distribution (RMD).
You must take your first required minimum distribution for the year in which you turn age 72 (70 ½ if you reach 70 ½ before January 1, 2020). However, the first payment can be delayed until April 1 of 2020 if you turned 70½ in 2019.
If an account owner fails to withdraw an RMD, fails to withdraw the full amount of the RMD, or fails to withdraw the RMD by the applicable deadline, the amount not withdrawn is taxed at 50%. The account owner should file Form 5329, Additional Taxes on Qualified Plans (Including IRAs) and Other Tax-Favored Accounts, with his or her federal tax return for the year in which the full amount of the RMD was not taken.
The penalty may be waived if the account owner establishes that the shortfall in distributions was due to reasonable error and that reasonable steps are being taken to remedy the shortfall. In order to qualify for this relief, you must file Form 5329 and attach a letter of explanation. See the instructions to Form 5329.
