I turned 70 in November 2019. I was planning on taking my first required minimum distribution (RMD) in May 2020 (when I turned 70½) until the government waived 2020 RMDs. Is my first RMD now due by May 2021? Also, I have two IRAs. Must I withdraw the RMD amount from each one, or can I withdraw enough from one account to cover the total RMD amount required from both?

The Internal Revenue Service sees your traditional individual retirement accounts as a single pool of money. You can withdraw your total RMD amount from one IRA or from any combination of IRAs.

You're right that the federal CARES Act waived 2020 RMDs. But another recent law applies to you, too — the federal SECURE Act. For everyone born after June 30, 1949, the SECURE Act changed the first RMD deadline from April 1 of the year after age 70½ to April 1 of the year after age 72.

If you turned 70 in November 2019, you were born in November 1949; so your first RMD is due by April 1, 2022. But subsequent RMDs are due annually by Dec. 31. So it would be sensible to take your first RMD in 2021. Otherwise, you'll have to take two RMDs in 2022.

What about people whose first RMD deadline was April 1, 2021? That April 1 deadline applied to 2020 RMDs, which are waived, says Ed Slott, a Rockville Centre tax accountant. Those people don't have to take an RMD until Dec. 31, 2021. Technically, it's their second RMD, thanks to the 2020 waiver.

The bottom line

RMD rules have changed. It's smart to double-check which ones apply to you.

More information

nwsdy.li/IRSSecureActFAQ

nwsdy.li/IRSrolloverReliefCARESAct

Note about Jan. 3 column: An application for Social Security as a divorced spouse can't be filed until two years after the divorce.

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