12 month ira rollover

Submitted by gregory pierce on Mon, 2019-07-01 19:34

I have a 72 year old client with 2 IRA’s and taking monthly distributions from each.
On April 23 he requested and received an additional $10K withdrawal from IRA#1
On June 3 he again requested and received an additional $50K withdrawal from IRA#1
On June 21 he deposited $10K to IRA#1 coded as a rollover contribution.
I understand only 1 IRA rollover is allowable in 12 months.
I read your comment on the rules stating that a $100K withdrawal from an IRA could be rolled back in with 10 deposits ( I’m guessing these deposits need to be made on the same day).
Can my client make additional deposits up to $40K to create a $50K rollover contribution (done within 60 days of June 3)?
Or, does the $10K rollover contribution have to be applied against the 1st withdrawal?
Thank you!

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Permalink Submitted by David Mertz on Mon, 2019-07-01 21:29

Yes, assuming that there have been no other IRA distributions rolled over in the period beginning one year prior to the June 3 distribution, [except for any amount that was RMD for IRA#1 as Alan_iracritic mentions below] the $10k deposited as a rollover contribution on June 21 can be treated as a rollover of $10k of the June 3 distribution and the remaining $40k of that distribution can be rolled over in one or more additional rollover contributions up through the 60th day following June 3. None of the April 23 distribution would be treated as rolled over.

Permalink Submitted by gregory pierce on Tue, 2019-07-02 13:52

So to be sure – multiple deposits to equal the $50K rollover contribution can be made on different dates as long as all are within the 60 day window starting June 3. Correct? Thank you!

Permalink Submitted by Alan - IRA critic on Tue, 2019-07-02 00:09

In addition to the one rollover limitation, the client cannot roll back any distribution from IRA 1 until the RMD for IRA has been completed. As of 6/21 he has distributed from IRA 1 the monthly distributions paid to that date plus 60k. While the total probably exceeded the RMD for IRA 1 by at least 10k, if it didn’t the 10k rollover already done was not allowed because it was an RMD. To make this even more complex, the monthly distributions from IRA 2 up to 6/21 can also be credited to the RMD balance for IRA 1 with respect to whether the rollover already done was allowed. If the RMD for IRA 1 has not been completed client needs to limit the amounts rolled back to IRA 1 to make sure that they do not result in RMD money for IRA 1 being rolled back into either IRA. Since these rules are complex, client needs to pencil this out before rolling back any more. There may be no problem with the actual numbers you posted, but this random distribution and rollover pattern is prone to error if client is not checking all the numbers.

Permalink Submitted by David Mertz on Tue, 2019-07-02 01:50

For the $10k already rolled over to have been an impermissible rollover of any part of the 2019 RMD for IRA#1, IRA#1 would had to have had a 2018 year-end balance of something substantially exceeding of $1M.

Permalink Submitted by gregory pierce on Tue, 2019-07-02 14:10

I just now noticed the discussion on the RMD as a factor on this rollover. IRA#1 ( brokerage acct consisting of mutual funds) has a 2019 RMD of $32,397 and client is taking $4K/mo so has received $24K through June. IRA#2 ( VA with an income rider and taking the max) has a 2019 RMD of $15,086 and client is withdrawing $2,412.14/mo so has received $14,472.84 through June. Are we okay to add deposits to the rollover up to another $40K ?Thank you!

Permalink Submitted by David Mertz on Tue, 2019-07-02 15:26

If the $4k monthly distribution from IRA#1 for June occurred prior to or on June 3, a total of $34k would have been distributed prior to the June 3 $50k distribution. That $34k would be sufficient to cover IRA#1’s RMD, so the full $50k distributed on June 3 would be eligible for rollover. Let us know the date of the monthly $4k distribution for June.
If the monthly $4k distribution for June occurred after June 3, things are a bit more complicated. In that case, distributions from IRA#1 prior to June 3 would be only $30k, so $2,397 of IRA#1’s RMD would remain to be satisfied by IRA#1 distributions prior to the June 3 $50k distribution. Simplest would just be to say that only a total of $47,603 of the of the June 3 distribution is eligible for rollover, including the $10k already rolled over, meaning that an additional $37,603 is eligible to be rolled over. However, it might be possible to treat some of the distributions from IRA#2 as satisfying the remaining $2,397 RMD of IRA#1 prior to June 3 even though IRA#2’s RMD might not be satisfied by June 3. I would be interested to hear Alan_iracritic’s thoughts on this: Can a distribution from IRA#2 be treated as satisfying any of IRA#1 RMD before IRA#2’s RMD has been satisfied?
Unless contractually obligated to take $4k distributions from IRA#1 every month, an alternative to rolling over the full $50k would be to reduce monthly distribution amounts that remain to be distributed for the year (unless the plan already was to stop those monthly distributions from IRA#1).

Permalink Submitted by Alan - IRA critic on Tue, 2019-07-02 22:36

Yes, I interpret Reg 1.408-8, QA 4 and 9, as indicating that the IRA aggregation rules apply to the RMDs for all IRAs. Therefore, once the RMD FOR IRA 1 has been satisfied from any owned IRA account, a later distribution from IRA 1 can be rolled over. That would mean that the entire RMD FOR IRA 1 could be satisfied from IRA 2, and the first distribution taken from 1 could be rolled over as long as it was distributed after the RMD for 1 was satisfied. In this case there are distributions taken from both IRA accounts that satisfy the RMD for either or both of those accounts. This interpretation can also be used to convert from an IRA for which the RMD for that account has been completed, so if that is a smaller account the conversion could occur before the total RMD for all accounts has been completed.
Another post was made today on behalf of this same client that also indicated that the 50k distribution was to purchase a home for a child (not clear if a first home for that child), but the deal fell through. If this distribution did qualify (not yet known) as a first home distribution, that could provide 120 days to roll it back as long as none of it was needed to complete the RMD amount FOR IRA 1. In that case the first home distribution would not count against the one rollover limitation so would be allowed.
I doubt that the interplay between the RMD aggregation rules and the rollover rule for distributions from a particular IRA is on the IRS’ radar.

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