When you look at the markets and the economy today, it’s amazing how different things feel than they did a year ago. Hopes for widespread adoption of COVID-19 vaccines and a host of fiscal and monetary incentives has many economists forecasting the most significant growth in 2021 we have seen in decades. In contrast, the spring of 2020 was filled with dire economic forecasts of global depression and economic consequences for years into the future.
Unsurprisingly, many people sought financial measures to cushion the blow. People who lost their jobs during the economic stalemate had to wait weeks and months for unemployment benefits to arrive. Even those who continued to have their sources of income found the need to cushion their bank accounts under the face of darker days ahead. For many, this meant taking on distributions of 401k and IRA accounts.
In any normal year, a distribution of deferred tax assets from a retirement account is taxable in the year in which it is distributed. Additionally, Distributions before the age of 59 ½ years (with a few exceptions) are subject to additional taxation, usually 10%.
However, an exception has been introduced under the CARES Act that can give people more flexibility and potentially less taxes on distributions from these plans. The specific terms apply to a redefined element called “Coronavirus Related Distribution (CRD)”. Distributions falling into this category up to a total of $ 100,000 made between January 1, 2020 and December 30, 2020 may receive three specific types of special treatment.
CRD Special Treatment 1: Distribution of Income
As noted above, retirement benefit distributions are typically taxed as income in the year they are drawn. However, distributions that are considered to be coronavirus-related can span 3 years.
Example: Gary took over a distribution from his IRA from $ 30,000 in January 2020. He determines that he would be eligible for a CRD. He may report $ 10,000 of that distribution as income in 2020, another $ 10,000 in 2021, and finally another $ 10,000 in 2022.
Assuming that someone has to make such a distribution under unfavorable financial conditions, it can be very helpful to spread taxation over the distribution, especially as conditions for the taxpayer improve in the years to come.
The 3 year tax treatment is not required – and someone who made a distribution from their IRA or 401 (k) in 2020 to cover their loss of income might consider treating EVERYTHING as a 2020 distribution for tax purposes, in particular if he regains his earned income in future years. If you take it all in a year when income was lower, the marginal tax rate paid may decrease.
CRD special treatment 2: No withholding tax required
Distributions from qualifying plans like 401,000 generally require a 20% withholding tax. It doesn’t help if someone doing an emergency distribution has to withhold so much, especially if they are able to spread the tax over 3 years. Therefore, plan administrators who distribute money for CRDs did not have to withhold federal tax on those distributions.
CRD special treatment 3: No penalty for early withdrawal
Coronavirus-related distributions are not subject to the normal 10% penalty for taxpayers who make distributions before the age of 59 ½ years. In our example above, Gary wouldn’t have to pay the 10% additional tax even if he were 30 years old in 2020.
CRD Special Treatment 4: Repayment is an advantage
One final exception to the rules is the repayment of a coronavirus-related distribution. Typically, when you take money out of an IRA or Eligible Plan, it must be returned within 60 days to qualify as an “indirect rollover”. These can only be carried out once in a twelve-month period. However, CRDs can be repaid at any time during the three-year period for 2020, 2021 and 2022. This not only enables more flexibility in terms of taxation. it can Helping people reverse the damage early withdrawal has done to their retirement plans.
Example: Vicki took $ 60,000 from her IRA in 2020. She opted for the three-year tax treatment and paid income tax on $ 20,000 on distributions on her return in 2020 and an additional $ 20,000 on her return in 2021. In 2022, she received an inheritance and decided to withdraw her CRD distribution of USD 60,000 to be repaid. She won’t owe the taxes for the portion of 2022 that would have been $ 20,000. She can also amend her 2020 and 2021 tax returns to include the tax she paid on the other $ 40,000.
What exactly qualifies a distribution as a CRD? This answer is not very clear. The IRS lists some specific items This would entitle a taxpayer to make distributions even if they had a COVID-19 diagnosis or was in their household, or if they were on leave, laid off or unable to work due to COVID.
It is interesting, however, that distributions can qualify until January 1, 2020 if nobody would have fallen into those categories. The IRS guidelines specifically state that additional guidelines can be issued to expand the list of factors that would qualify a person for CRDs. If you have a question about whether your distributions may qualify in 2020, get an opinion from your tax advisor first, and then work with your advisor to see if you benefit from the CRD regulations.
If you qualify, there is a special form that was only available in final form from the IRS a few weeks ago. You can use Form 8915-E to report a CRD and choose tax treatment.
Indeed, 2020 was a year of great uncertainty and upheaval. CRDs are one of several ways the U.S. government has mitigated some of the impact. Use this provision if you can!