Is anyone familiar with the Self Certification for Late Rollover Contributions?

[AnmarieA]

I have a client who did not rollover a death benefit 1099R distribution in error and did not realize this until after the 60 day period. There is an IRS Revenue Proc 2016-47 that references this self certification. Is anyone familiar with this?

[qbteachmt]

Have you checked to see if the coronavirus provisions apply? That might be easier.

[AnmarieA]

The literature does not specifically state COVID19 as a reason but I plan on using it. 

[qbteachmt]

"The literature does not specifically state COVID19 as a reason but I plan on using it."

The reference you pointed to has the provision for Disaster declaration. Now you follow the CARES ACT for what it included, which includes RMD waiver, and Rollover Treatment for them that is specifically more than the 60-day limit and avoids the "one per 12 month" restriction, as well.

In fact, If you took distribution, you would have 3 years to repay it and have it treated as a rollover.

An RMD would be redeposited by Aug 31 to be treated as ignored.

All of that is in the CARES provisions.

https://www.investopedia.com/how-the-coronavirus-stimulus-bills-affect-you-4800404

"Special Rules for Retirement Funds (Phase 3)

(3) The CARES Act effectively waives the 10% tax penalty for early withdrawals from retirement funds if those withdrawals are related to the coronavirus. The waiver is retroactive to Jan. 1, 2020. In addition, those who withdraw from retirement funds have up to three years to either pay the income tax due on the withdrawal (normally due the same year) or redeposit the funds withdrawn with no tax penalty. IRS guidance expanded eligibility for IRA, 401(k) withdrawals up to $100,000 for people who started a job late, had a job offer rescinded, or were spouses with retirement accounts affected by COVID-19, in addition to those directly affected by the coronavirus.22

Also, account owners subject to required minimum distributions (RMDs) from their retirement accounts do not have to take RMDs in 2020 to allow time for the funds to build up again.8"

And the IRS has lots of specific notifications, as these things got passed the notifications were issued:

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

The disaster distribution eligibility is right in the Form 8915-E instructions:

https://www.irs.gov/pub/irs-pdf/i8915e.pdf

[qbteachmt]

Oh, sorry: My point is that there are lots of provisions. You don't need that Self-Certification provision. That is overthinking this.

[qbteachmt]

@AnmarieA 

I don't see where you followed up on your issue here. For instance, this IRA beneficiary, if the surviving spouse, could treat this as a coronavirus disaster distribution and would have 3 years to "roll it over."

Also, I came across this:

Rev. Proc. 2020-46

SECTION 1. PURPOSE

This revenue procedure modifies and updates Rev. Proc. 2016-47, 2016-37 I.R.B. 346.

Which doesn't seem like the best option for your scenario; I thought you might want to document it for future reference, though.