Using 60-day rollover rules to stretch time to do Roth conversion analysis

I’m hoping to get more clarity on my 2020 tax situation before making a 2020 Roth conversion. Can I take money out of my IRA on December 25 (for example), hold it out until my tax return can be done, and then either deposit the money to a Roth (as a conversion) or back into the IRA (60-day rollover)? No – I have not used up my one rollover in the last year.

If so, could I do a combination where (for example) I take out $50k in December and I stuff $35k into a Roth and the rest back into my IRA? Would this count as two rollovers?

Thanks for any help anyone can provide.



  • Yes, you can do that as a 60 day rollover. The conversion 5 year holding period would start in 2021. You can even request 2020 withholding on the distribution and come up with other money to make your 60 day rollover amounts complete. The one rollover rule does not apply to the conversion portion, but it does for any funds rolled back to a TIRA account.  You can do the combination if you wish, as it only uses one rollover for purposes of the one rollover in 12 months limitation.
  • The 1099R will be issued in January for 2020, but the 5498 will not be issued until May, 2022 since the rollover contributions will be done in 2021. The IRS understands that the 5498 and 1099 R may not sync up for this reason, but they might still ask about the rollover date.

Thank you for the quick reply!  How amazing it is to have this board (and you!) as a resourse.

I received an RMD from my Traditional IRA in February 2020. I returned it by a check to the same IRA on August 3, 2020. Does the August 3, 2020 date establish the start date for the one year rollover limitation i.e. the next available rollover date would be August 3, 2021 or later. Is the return of a 2020 RMD exempt from the one year limitation rule going forward? I had no earlier rollovers for several years prior.  I have both Traditional and Roth IRAs.

  • IRS Notice 2020-51 says that the rollover of what would have been an RMD were it not for section 2203 of the CARES Act is disregarded with respect to the one-rollover-per-year limitation.
  • If this limitation was instead not to be disregarded, the one-year period with respect to this rolled-over distribution would have begun on the February 2020 date on which the distribution was received.

Can I do a rollover back to the original TIRA of 2 month’s distributions plus a withholding distribution as long as all 3 are rolled within 60 days with a single repayment?

No more that one of the distributions, including its associated tax withholding, can be rolled back now.  The limitation is on the number of *distributions* that can be rolled back, not on the number of rollover deposits.  The deadline for repayments allowed by Notice 2020-51 was August 31, 2020 and is no longer relevant.

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