Once-a-Year IRA Rollover Limit

Posted by Lee Reams Sr. on

Back in 2014 the IRS, in Announcement 2014-15, notified taxpayers that they were adopting the Tax Court position in Bobrow v. Commissioner (TC Memo 2014-21) that the once-per-year IRA rollover limitation applies on an aggregate basis, meaning that an individual could not make an IRA-to-IRA rollover if he or she had made such a rollover involving any of the individual’s IRAs in the preceding 1-year period. The question is how is that 1-year limit measured?

Per IRC Sec 408(d)(3)(B), the one-year period is measured based on the date a distribution is received.  If the second distribution is received before the same date one year later, it occurs within the period barred by the one-year limit.