Regulatory Updates

IRS Revises Rollover Self-Certification Rules

October 19, 2020 – The IRS has issued Revenue Procedure (Rev. Proc.) 2020-46, which modifies earlier guidance describing the process by which taxpayers can self-certify their eligibility for an extension of the 60-day deadline to complete an otherwise-eligible rollover. 

Previous IRS guidance (Rev. Proc. 2016-47) identified circumstances under which a taxpayer would be eligible to extend the normal 60-day period in which to complete a rollover, and the procedure by which one can self-certify that eligibility. Rev. Proc. 2020-46 now adds to these qualifying circumstances amounts that are recovered by a taxpayer after being distributed and paid “to a state unclaimed property fund.” 

This new guidance does not modify in any manner other conditions necessary for rollover eligibility. (Rev. Proc. 2020-46 was issued simultaneous to IRS Revenue Ruling 2020-24, which describes withholding and reporting obligations of qualified retirement plans that escheat amounts to unclaimed property funds.)