The tax law definition for Qualified Higher Education Expenses (QHEE) was amended (signed into law in December of 2019) to include student loan payments (to a maximum of $10,000).
529 withdrawals that are not considered QHEE are subject to income tax on the gains as well as penalties.
This question is about timing of student loan payments as they relate to the associated withdrawal from the 529 account. I see other questions about this tax law change, but none that directly address just this one aspect of timing.
During 2019, $5,000 was paid towards existing student loans. No other QHEE's happened during during 2019. No 529 withdrawals were made in 2019 [Clarification: earlier tuition and other QHEE were made in 2017 and earlier, although I don't thing this has any impact on the question].
For the above scenario, can $5,000 be withdrawn (in 2020) from the associated 529 account without interest and penalties? [Clarification: to reimburse myself for the 2019 student loan expense]