k man

A says you have until december 31 to delay. B says ALL subsequent payments are adjusted to reflect the one year delay. if you do it the other way you aren't delaying all subsequent payments are you?

(2) Delay of repayment.--In the case of a qualified individual with an outstanding loan (on or after the date of the enactment of this Act) from a qualified employer plan (as defined in section 72(p)(4) of the Internal Revenue Code of 1986)-- (A) if the due date pursuant to subparagraph (B) or (C) of section 72(p)(2) of such Code for any repayment with respect to such loan occurs during the period beginning on the date of the enactment of this Act and ending on December 31, 2020, such due date shall be delayed for 1 year, (B) any subsequent repayments with respect to any such loan shall be appropriately adjusted to reflect the delay in the due date under subparagraph (A) and any interest accruing during such delay, and (C) in determining the 5-year period and the term of a loan under subparagraph (B) or (C) of section 72(p)(2) of such Code, the period described in subparagraph (A) of this paragraph shall be disregarded. under (A) You delay payments due until December 31 for one year under (B) you adjust subsequent loans repayments to reflect the delay. i read that to mean you adjust all future payments back one year. it just makes no sense to do it the other way. frankly who is going to complain if you interpret it either way?

i agree with this. it is the only logical interpretation.

it makes no sense to do it this way.

not a CPA but wouldn't the taxpayer be able to use the taxes paid as a credit to apply to income for that year?

CARES Act says tax is ratable over three years. lets say he pays back the distribution in year 3. what happens to the tax paid?

mike, how would the COVID loan work in terms of the limit if he already has an existing loan. lets say his account balance is 100k but he already has an existing loan. i i am guessing he can take 100% less the amount of the existing loan?

maybe it is semantics but it is optional. people who want to take from their IRA can and people who don't are not forced to.

larry do you think they could just reclassify the RMD they took from their IRA as a COVID and put it back anytime over the next 3 years? i have been thinking about the 60 day and what would happen if the distribution was more than 60 days ago.

i think RMD's are waived but participants can take an optional distribution of any size from their IRA or a DC plan. otherwise people would be forced to take a COVID distribution.

is spousal consent still required? can't find it anywhere.

https://news.bloomberglaw.com/employee-benefits/hardship-401k-withdrawal-penalties-waived-in-u-s-relief-bill does anyone know what made the final package (sausage)?

an extension is a no brainer. plans aren't even submitted anymore. if for no other reason give people one less thing to worry about in these trying times.

nothing in the ARA proposal looks to be directed to relief for participants.

just posted on the db board before i saw this. looking for information on whether there is a db extension. doesn't seem to be a big deal for the IRS.