60 Day Rollover Over Two Tax Years

Hello

Interested to learn if an IRA owner could use a 60 day rollover spanning two years to split an initial distribution into two tax years. Ex. Client only has one IRA; they take the first distribution for $190K from their IRA in late November with the intension to rollover 1/2 of that distribution in early January 2024. Client takes another distribution of $95K in early January 2024 and then subsequently returns or rollovers back to their IRA $95K within 60 days from the initial $190k distribution taken in late November. Will the client successfully have taken a distribution of only $95k in 2023 since half of the original distribution was rolled over within 90 day and then also a distribution of $95k in 2024 therefore splitting the total needed distribution of $190k over two tax years? Clearly the client would need to be very careful to roll the $95k back to their IRA within 60 days of the November distribution but are there any issues with using the second distribution to technically constitute half a rollover of the first distribution? Thank you!



This should be OK because only one distribution is being rolled over and two calendar years being involved is immaterial. Client would report a 190k distribution and 95k rollover on the 2023 1040 and a 95k distribution (no rollover) on the 2024 1040. Due to the one rollover limit client could not take another distribution from which any portion would be rolled over until one year and a day from the day of the Nov 2023 distribution. 



Thank you very much!



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