Rollover from ROTH IRA to ROTH solo 401k under CARES Act?

[Mike S.]

You can not rollover funds from a ROTH IRA to a ROTH solo 401k per the IRS rollover matrix.

Under the CARES Act you can take a $100k withdrawal/distribution without penalty from your IRA or QRP, and if you repay it into a retirement plan within 3 years, you won't pay tax on it. The repayment is re-characterized as rollover.

Can one takes a COVID related distribution from a ROTH IRA, and repays it into a ROTH solo 401k within the 3 years, creating a defacto backdoor ROTH IRA to ROTH 401k rollover?

[Carl Fischer]

@Mike S.

I don't think the Roth IRA to Roth 401k will work. However, it is a great question and we will see in the future when the rules are better articulated.
The taxation on the Roth IRA considering contributions and earnings are still not clear on how to handle. Understanding your basis and earnings is going to be key.