The IRS has announced further guidance on the once per year rollover limitation that goes into effect on January 1, 2015. Here is the gist of the IRS notice:
The new interpretation of the once per year rollover rule applies to distributions from different IRAs if distributions occurs after 2014.
Under the transition rule – “a distribution occurring in 2014 that was rolled over is disregarded for purposes of determining whether a 2015 distribution can be rolled over under Code Sec. 408(d)(3)(A)(i), provided that the 2015 distribution is from a different IRA that neither made nor received the 2014 distribution.”
Interpretation: a distribution received in late 2014 can be rolled over in 2015, as long as it is done within 60 days, without preventing a 2015 distribution from a different IRA from being rolled over.
The new restriction does not apply to trustee-to-trustee transfers. The IRS encourages IRA trustees/custodians to offer trustee-to-trustee transfers to IRA owners.
The new restriction does not apply to rollovers to or from a qualified plan.
A traditional IRA conversion to a Roth IRA is not subject to the once per year rollover limit per-year limitation.
A rollover between Roth IRAs or between Traditional IRAs does preclude a separate rollover within the 1 year period. (“Traditional” includes Simple IRAs and simplified employee pensions).
Example: if you do a rollover between Roth 1 and Roth 2 in 2015, you can’t then do a rollover between Traditional 1 and Traditional 2 within 1 year.
Source: IRS Ann. 2014-15, United States Tax Reporter