IRA to IRA transfer at same custodian

I want to have a Traditional IRA with charities as beneficiaries, separate from the one that has human beneficiaries. That will hopefully eliminate any risk of a 5-year withdrawal forced for the human beneficiaries. They will both be at the same custodian, Vanguard. Language about direct transfers for IRAs usually means between custodians. I want to be able to transfer money between the IRAs perhaps twice a year or quarterly for rebalancing, but am concerned those may be considered rollovers and limited to one per 12-month period, even though money never comes directly to me. Is there a link that clarifies these as being direct transfers as well?

Thank you in advance for your help.



  • A same trustee transfer is handled just like a direct transfer between different trustees. It is not a distribution, does not generate a 1099R, is not reported on your tax return, and you can do unlimited numbers of these transfers. Since the transfers are not distributions, the one rollover limit does not apply. See p 21 of IRS Pub 590-A linked below.
  • 2021 Publication 590-A (irs.gov)


Thank you very much! 



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