Under the CARES Act, if I use a portion of my qualified 401k withdrawal to pay an pre existing 401k loan, does that qualify as a partial repayment contribution of this special withdrawal?

[macuser_22]

No.  And you must be qualified to take a distributiin under the CARES act at all.

See Q3:

https://www.irs.gov/newsroom/coronavirus-related-relief-for-retirement-plans-and-iras-questions-and-...

Q3. Am I a qualified individual for purposes of section 2202 of the CARES Act?

A3. You are a qualified individual if –

• You are 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;

• Your spouse or dependent is diagnosed with SARS-CoV-2 or with COVID-19 by a test approved by the Centers for Disease Control and Prevention;

• You experience adverse financial consequences as a result of being quarantined, being furloughed or laid off, or having work hours reduced due to SARS-CoV-2 or COVID-19;

• You experience adverse financial consequences as a result of being unable to work due to lack of child care due to SARS-CoV-2 or COVID-19; or

• You experience adverse financial consequences as a result of closing or reducing hours of a business that you own or operate due to SARS-CoV-2 or COVID-19.

Under section 2202 of the CARES Act, the Treasury Department and the IRS may issue guidance that expands the list of factors taken into account to determine whether an individual is a qualified individual as a result of experiencing adverse financial consequences. The Treasury Department and the IRS have received and are reviewing comments from the public requesting that the list of factors be expanded.

[Critter-3]

Personally if you are allowed by the employer to take a distribution from the 401K  then what you use it for is immaterial including paying off any kind of loan. This would be no difference than paying off a car or mortgage. 

[NathanDubraska]

Am I still considered a qualified individual if a member of the household (not a dependent) is impacted financially due to COVID-19 (reduced work hours, loss of job, etc.)? See https://www.irs.gov/pub/irs-drop/n-20-50.pdf

States in part the following; 

"In addition, pursuant to the authority of the Secretary to issue guidance to
provide for other factors under section 2202(a)(4)(A)(ii)(III) of the CARES Act, a
qualified individual for purposes of this notice is an individual who experiences
adverse financial consequences as a result of:
• the individual having a reduction in pay (or self-employment
income) due to COVID-19 or having a job offer rescinded or start
date for a job delayed due to COVID-19;
• the individual’s spouse or a member of the individual’s household
(as defined below) being quarantined, being furloughed or laid off,
or having work hours reduced due to COVID-19, being unable to
work due to lack of childcare due to COVID-19, having a reduction
in pay (or self-employment income) due to COVID-19, or having a
job offer rescinded or start date for a job delayed due to COVID-19;
or
• closing or reducing hours of a business owned or operated by the
individual’s spouse or a member of the individual’s household due
to COVID-19.
For purposes of applying these additional factors, a member of the individual’s
household is someone who shares the individual’s principal residence."

[Critter-3]

@NathanDubraska 

First you posted to an old thread ...  and since that old posting they amended the rules to include  " the individual’s spouse or a member of the individual’s household"  where is used to only be the person making the withdrawal.