A client recently passed away and we are in the process of doing a spousal rollover to the husband’s IRA (who is incapacitated). At the same time, the daughter wants to mazimize the growth of a Residual (“B”) trust by taking a growth asset out of the IRA and swapping it with cash that will be going to fund the “B” trust so as to maximize the growth of the “B” trust. There will be no change in the dollar values of the “B” trust or IRA.

Question: Is the death rollover and the “swap” considered two rollovers? And is it considered a one person rollover? I’ve poured over the IRS regs and can’t find anything on this.