Bobrow V. Commissioner
The IRS issued Announcement 2014-15 regarding the application of the one per year limit on IRA rollovers: http://www.irs.gov/pub/irs-drop/a-14-15.pdf
They will not apply the Bobrow interpretation to any rollover that involves an IRA distribution ocurring before January 1, 2015. They will be issuing a proposed regulation that would clarify that the IRA rollover limitation applies on an aggregate basis.
There is a long time between now and January 2, 2015 and I’m guessing there will be lot of opposition to the proposed regulation by the financial industry so who knows what we will actually end up with in 2015.
Permalink Submitted by Alan - IRA critic on Thu, 2014-03-20 21:35
Thanks for the update. Am a little surprised that the IRS jumped on this given the enforcement implications, but it’s possible that they will push the custodians to enforce this up front, but not be looking aggressively for those that slip through and many will due to custodian limitations resulting from not holding all of a taxpayer’s IRA accounts. All the IRS would have to do is look for more than one 1099R-5498 match for a taxpayer that did two large rollovers and the consequences would be severe.