Need Help Understanding CARES Act COVID Withdrawal Repayment and Roth IRA Conversion
I've been searching everywhere and haven't found a clear answer for my situation. Here's what I'm dealing with: Back in June 2020, I took a CARES Act withdrawal from my 401k due to financial hardship during COVID. The amount was about $28,000 which is way more than the annual Roth contribution limit. Around the same time, I also moved my remaining 401k funds - split 50/50 between a Traditional IRA and Roth IRA. I figured it was a good time since the market had dropped about 25% in the spring crash, and my income for 2020 was really low, so the Roth conversion tax hit wasn't too bad. Fast forward to now - my financial situation has improved and I'm thinking about converting the rest of my Traditional IRA to Roth this year since my income is still relatively low. The big question is: I can now repay the ENTIRE CARES Act withdrawal, but I'm confused about the tax implications. If I repay the full CARES withdrawal now, should I also go ahead with converting the remaining Traditional IRA to Roth? Would this mean I'm getting double-taxed - once on the CARES withdrawal and then again on putting those funds into the Roth? I know I won't have the early withdrawal penalty thanks to the CARES Act, but I'm trying to understand the most tax-efficient approach. Has anyone dealt with repaying a CARES Act withdrawal while also doing Roth conversions? I understand I'll need to wait for Form 8915-E from the IRS before completing my taxes. Thanks for any help!
19 comments


Andre Laurent
The CARES Act withdrawal and Roth conversion are actually separate tax events, so let me help clarify this for you. When you took the CARES Act withdrawal, you had three tax options: 1) pay all taxes in the year of withdrawal, 2) spread the income over three years (2020-2022), or 3) repay some or all of it within the three-year window to avoid taxation on the repaid portion. If you repay the full CARES Act withdrawal now, you'll essentially undo that distribution for tax purposes. If you already paid taxes on it for 2020, you can file an amended return to get those taxes back. If you're spreading the taxes over three years, you'll avoid future tax payments on that distribution. Regarding your Roth conversion question - converting your Traditional IRA to Roth is completely separate. You'll pay ordinary income tax on the converted amount in the year you do the conversion. Since you mention your income is still relatively low, this might be an ideal time. You're not being double-taxed on the same money. The CARES withdrawal and the Roth conversion are different pools of money with their own tax treatments. If you repay the CARES withdrawal, you avoid taxes on that money completely.
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Carmen Diaz
•Thanks for the explanation! So if I understand correctly, I can repay the CARES withdrawal and that's like it never happened tax-wise. And since the Roth conversion is totally separate, I won't be double-taxed? One more question - when I repay the CARES withdrawal, can I put that money directly into my Roth IRA instead of back into my 401k (which I no longer have access to)? Or does it need to go somewhere specific?
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Andre Laurent
•You've got it right - repaying the CARES withdrawal means it's like it never happened for tax purposes. And yes, the Roth conversion is completely separate, so no double taxation there. Regarding where to repay the CARES withdrawal, this is an important distinction. The repayment must go back to a qualified retirement plan where you're eligible to contribute. If you no longer have access to your former 401k, you can repay it to your current employer's plan (if you have one and they accept rollovers) or to your Traditional IRA - not directly to a Roth IRA. The repayment is treated as a rollover, not a contribution, so it doesn't count against your annual contribution limits.
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AstroAce
I used taxr.ai when I was in a similar situation with a CARES Act withdrawal and subsequent Roth conversion. I was totally confused about the tax implications and worried about making a costly mistake. After spending hours on IRS publications and getting conflicting advice, I stumbled across https://taxr.ai and uploaded my documentation. They analyzed everything and gave me step-by-step guidance on how to handle both the CARES Act repayment and my Roth conversion strategy. Their system detected that I had selected the 3-year tax spread on my CARES withdrawal but was planning to repay it, which would've created reporting complications. They explained exactly which forms I needed, how to document the repayment, and how to structure my Roth conversion to minimize my tax liability. Super helpful for navigating these complex retirement account transactions.
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Zoe Kyriakidou
•Did they actually help you figure out where to send the repayment? My old 401k plan was terminated after my company got acquired and I'm struggling to figure out where my CARES repayment should go. Does taxr.ai give specific instructions for this?
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Jamal Brown
•I'm a bit skeptical about these tax services. How did it actually work? Did you just upload your documents and they figured everything out? And did they just give advice or did they actually help you file the paperwork?
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AstroAce
•They did help me determine where to send the repayment. In my case, my old 401k was still active, but they explained that if it wasn't, I could make the repayment to any qualified retirement account - including my Traditional IRA. They provided specific instructions based on my situation, including sample letters to send with the repayment. Their process was straightforward - I uploaded my 1099-R showing the CARES withdrawal, my 401k statements, and answered questions about my tax situation. Their system identified the regulatory options and provided personalized guidance. They didn't file the paperwork for me, but they gave detailed instructions on how to report everything correctly on my tax return, including which forms to use and exactly how to fill them out.
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Zoe Kyriakidou
I wanted to follow up about my experience with taxr.ai after asking about it here. I decided to give it a try since my CARES Act repayment situation was driving me crazy. Honestly, it was so much more helpful than I expected! When I uploaded my documents, they immediately identified that my old 401k plan had been terminated (which was causing my confusion). They explained that I could make the CARES Act repayment to my Traditional IRA and provided exact instructions for how to code it with my brokerage so it wouldn't count toward contribution limits. They even created a custom letter template for me to send with my repayment and explained exactly how to report it on Form 8915-E when it becomes available. I've already made the repayment and feel confident about the tax handling now. This saved me so much stress and probably a lot of money in potential tax mistakes!
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Mei Zhang
I was in a similar situation with trying to repay a CARES withdrawal but kept getting stuck in endless IRS phone queues trying to get clarification. After three weeks of trying, I finally used https://claimyr.com to get through to an IRS agent. You can see how it works in this video: https://youtu.be/_kiP6q8DX5c They basically hold your place in the IRS phone queue and call you when an agent picks up. I was super skeptical at first, but I was desperate to get answers before the repayment deadline. I got a call back in about 45 minutes with an actual IRS representative on the line who confirmed exactly how to handle my CARES repayment and Roth conversion situation. The agent explained that I needed to make sure my financial institution coded the repayment correctly as a rollover contribution due to coronavirus-related distribution, and that I would need to file Form 8915-E. Having that official confirmation was so reassuring compared to getting conflicting advice online.
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Liam McConnell
•How does this actually work? I've been trying to get through to the IRS for weeks about my CARES repayment. Do they really get you through faster or are they just waiting on hold for you?
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Jamal Brown
•This sounds too good to be true. I've tried calling the IRS dozens of times about my retirement account issues and never get through. Why would this service be able to get through when regular people can't? Seems fishy to me.
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Mei Zhang
•They don't get you through faster - they basically wait in the queue for you. Their system dials continuously using algorithms to get in line, then when they reach a human, they call you and connect you. It's like having someone else do the frustrating hold time for you. They're simply using technology to handle the waiting part. Once you're connected, you're talking directly with an actual IRS agent - the service just bridges the call. I was skeptical too, but when I got connected to a real IRS employee who answered all my questions about Form 8915-E and CARES repayments, I was convinced. The agent even commented that more people were getting through because of these types of services.
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Jamal Brown
I need to eat my words about being skeptical. After seeing the responses here, I decided to try Claimyr because I was desperate to speak with the IRS about my CARES Act repayment situation. I've been trying for MONTHS to get official clarification. I used the service yesterday and got connected to an IRS agent in about an hour. The agent was able to confirm that my CARES Act repayment should go to my Traditional IRA since my old 401k is no longer available, and that it wouldn't count toward contribution limits. They also explained exactly how to document it for tax purposes. What would have been another month of stress and uncertainty was resolved in one conversation. The agent even explained how the upcoming Form 8915-E will work with my repayment situation. I'm honestly shocked at how well this worked after all my failed attempts to call directly. Sometimes you have to admit when you're wrong!
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Amara Oluwaseyi
Just a heads up about something nobody's mentioned yet - when you repay a CARES withdrawal, make sure you tell your IRA provider specifically that it's a CARES Act repayment! I repaid mine earlier this year and my provider initially coded it as a regular contribution, which would have put me way over the annual limit. I had to call them and have them recode it as a "rollover contribution due to coronavirus-related distribution" on their end. Also, keep VERY detailed records of everything - your original distribution paperwork, the repayment, and any tax forms. You'll need this documentation when you file your taxes and potentially for years afterward if you get audited.
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Carmen Diaz
•That's super helpful! Did your provider need any specific documentation from you to code it correctly? And did they give you any confirmation paperwork that I should ask for?
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Amara Oluwaseyi
•They asked for a copy of my 1099-R from the original CARES distribution to verify the amount and that it was coded correctly as a coronavirus-related distribution. They also had me fill out a form stating I was making a rollover contribution specifically for a CARES Act repayment. Definitely ask for written confirmation after they process it. I received a transaction confirmation showing "Rollover Contribution - CARES Act" which is important documentation to keep with your tax records. Some providers will also send a year-end statement specifically noting these types of transactions. Keep ALL of this paperwork for at least 7 years - this is the kind of unusual transaction that can trigger questions years later!
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CosmicCaptain
Has anyone considered the pro/cons of NOT repaying the CARES withdrawal? I took about $30k out and am now able to repay, but I'm wondering if it might actually be better to just pay the taxes (I selected the 3-year option) and keep the money out? My reasoning is that I'm 52 and might get more benefit from using that money now rather than having it locked away until retirement.
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Giovanni Rossi
•It really depends on your overall financial situation and retirement goals. The big advantage of repaying is you're putting money back into tax-advantaged accounts that can grow for another 10+ years until you retire. That compounding can be significant. However, if you have high-interest debt, need to build emergency savings, or have other pressing financial priorities, it might make sense to keep the money out. Just remember that if you're on the 3-year tax plan, you'll continue to owe taxes on those distributions for 2021 and 2022. Also consider your current vs. future tax brackets - if you expect to be in a much higher bracket in retirement, maybe the Roth conversion makes more sense than repaying.
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Connor O'Neill
I went through a very similar situation last year and want to share what I learned. First, definitely make sure you understand which tax treatment you originally elected for your CARES withdrawal - this makes a big difference in how the repayment works. One thing that caught me off guard was the timing. Even though you have until the 3-year deadline to repay, you need to make sure you do it in the right tax year if you want the tax benefits for that year. I almost missed this and would have had to wait until the following year to get my refund. Also, regarding your Roth conversion question - since you mentioned your income is still relatively low, this could be a great opportunity. You're essentially paying taxes now at lower rates to avoid potentially higher rates later. Just make sure you have enough cash outside of retirement accounts to pay the conversion taxes without touching the converted funds. Have you calculated what your total tax liability would be for both the CARES repayment (if you don't repay) and the Roth conversion? That might help you decide the optimal strategy.
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