60 Day Rollover Waiver Update

Ernie Guerriero, CLU®,ChFC®,CEBS,CPCU®,CPC®,CMS,AIF®,RICP®,CPFA

Friday, October 16, 2020, the IRS published a Revenue Procedure (2020-46) that updates a list of permissible reasons for self-certification of eligibility of a waiver of the 60-Day Rollover requirement.  The new reason added is for a distribution that was made to a State unclaimed property fund.  To be clear, a self-certification relates only to the reasons for missing the 60-day deadline, not to whether a distribution is otherwise eligible to be rolled over.

A taxpayer may make a written certification to a Plan Administrator or an IRA trustee that a contribution satisfies the conditions of the Revenue Procedure.  There must be:

• No prior denial from the IRS.
• The reason for missing the 60-day rollover (the Rev. Proc. outlines permissible reasons).  Generally, the reasons must be out of the individual’s control.
• The contribution must have been made within a 30 day safe harbor period.