Update On 1 Per Year Rollover Limitation

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

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