As most of you know the CARES Act was signed into law on Friday, March 27.  I attended an extensive Continuing Education session led by one of the nation’s experts and I spent time on Saturday learning more about how this new benefits package might help our clients.

Four provisions for individuals stand out:

Filing deadlines were clarified

• Tax filing and, perhaps more importantly payments for returns originally due on April 15^th and the tax estimates due on April 15th and June 15th have been postponed to July 15^th. You do not have to be sick or quarantined for this to apply. It applies to everybody. Furthermore, if you owe taxes, the period between April 15^th and July 15^th will be disregarded for calculating interest and penalties.  Those will begin to accrue on July 16^th if you owe money and haven’t paid by then. You can still extend filing your tax return to October 15^th by filing an appropriate extension on or before July 15^th.  Contributions to IRAs for 2019 can also be made up until July 15th .

No decision or action is needed on your part in order to take advantage of this postponement.

Checks in the mail

• It seems the most widely publicized provision of CARES is the “2020 Recovery Rebate for individuals.”  The intent of Congress is to drop money into bank accounts as soon as possible. They will do it electronically if you have had direct deposit of government benefits such as Social Security or a bank link for payment of taxes.  Obviously, the hope is that it will be a relief to families that are hurting from the effects of the virus and that it will flow back into the economy.

To calculate the amount, the IRS will be looking at your 2019 tax return (2018 if you haven’t yet filed 2019).  If you didn’t file a return in either year, but had Social Security income, they will look to your SSA-1099 and determine eligibility from that.  Based on their determination, they will send you $1,200 if you are single or $2,400 if you are married filing jointly, plus $500 for each child under the age of 17.  The rebate is not considered taxable income for 2020 but there are limits to amount of rebate. 

The rebate phases out at certain levels of adjusted gross income. If AGI exceeds $75,000 ($150,000 for joint filers and $112,500 for heads of household), your rebate is reduced by 5% of the amounts over those thresholds. 

It’s important to know that any payment you receive is an advance payment of a credit that will be calculated by your tax preparer and will appear on your 2020 tax return. In other words, the actual credit is based on 2020 income, not 2019 or 2018.  Plan accordingly. We anticipate that we will need to update any previously prepared tax projects as soon as the software catches up with these new laws and certainly before year-end.

Decision needed: No decision or action is needed to receive the money. But remember that there are five things, and only five things, to do with every dollar that comes to you, including this one.  Decide now, even before you get it, whether you are going to use it pay taxes, pay on debt, give it away, save it, or spend it.

Changes to retirement plans

• Required Minimum Distributions (RMDs) from retirement plans have been waived for 2020, including those who have a required beginning date in 2020.  Additional notices from the IRS have clarified the rules relating to the waiver. For example, you are now able to rollover any RMDs taken this year as long as you do it before August 31. Ordinarily you are only allowed to do one such rollover per year and it must be done within 60 days of the distribution. Both those requirements are waived. If you have a question about that, call us.  

• Early distributions from retirement plans (typically those made before age 59½) have previously been met with a 10% penalty in addition to the income taxes on the distribution.  Now, individuals can take up to $100,000 coronavirus-related early distribution (typically under 59½) from retirement plans without paying the 10% penalty.  These are available for those diagnosed or whose spouse is diagnosed with COVID-19, or those who experience adverse financial consequences as a result of COVID-19. The distribution will still be treated as income but will be recognized and taxed over 3 years rather than all at once in 2020. The amount distributed can be re-contributed over a three-year period as well. There are exemptions from the withholding rules. Before taking the distribution, consult your tax advisor. We can also assist you with this decision.

• Loans from retirement plans may become necessary for many people if cash gets really tight due to lack of work. In the past, loans have been limited to 50% of the account balance or $50,000. This has been increased to $100,000 limit and 100% of the account balance. This applies to loans made within 180 days of enactment.

Decision or Action: Strongly consider the impact of taking money out of your retirement account either by loan or distribution.  It is possible that you will miss the recovery of your 401k balance if you take the money out while the market is down.  Have your advisor run new retirement projections to determine the impact.  Weigh all the alternatives.

Charitable contributions deduction for non-itemizers

Charitable organizations need our help now more than ever.  CARES modified the charitable contribution deduction.  First, it provides non-itemizers the ability to deduct up to $300 of contributions from AGI.

For those who do itemize, percentage limitations are eliminated for this year.  The prior limit for contributions was 60% of Adjusted Gross Income (AGI), now it’s up to 100% of AGI; excess contributions can still be carried forward and used in future years. This means that your taxable income can be reduced to zero for 2020 by carefully planning your major contributions to match your AGI. This technique is not available for contributions made to donor-advised funds.

Decision or action: Make a contribution to your favorite charities now for at least $300. They likely need it now more than ever.  Remember to take the deduction next year, even if you don’t itemize.     

Watch for a complete post on the ability to deduct 100% of AGI this year.  It is also a way to make a tax-free conversion of IRA to a ROTH-IRA.   Coming up soon.         

Student loans

As a result of the pandemic, Congress has halted all federal student loan interest accumulation and payment requirements through September 30. Borrowers may continue to make payments during this time, but no financial penalties will apply if no payments are made. If you are in a loan-forgiveness plan (e.g. those working in a not-for-profit organization), these months will count toward loan forgiveness plan as if the payments had been made.

Decision or action: If you have a loan that is not a federal loan, you should reach out to your lender.

As I said at the beginning of this, each member of our firm is hard at work serving clients during this crisis. But we are here for you.   All of us are likely to face challenging decisions in the days and weeks ahead. Reach out via email, call, text or ZOOM.

This post was updated for new information on June 27, 2020.