Would a split Rollover constitute one or two in 12 mos

In a case where the appropriate amount of a Roth Conversion depends on year end tax calculations, can a person take a distribution from a TIRA in late December and then within the 60 days deposit a portion into a Roth IRA as a conversion and the balance back into a TIRA all within the 60 days? Would this meet the requirement of only one rollover in a 12 month period or would it be treated as two?



Rollovers are determined by the number of distributions that are partially or fully rolled over, but conversions do not count. In this case, if the entire distribution was converted, there would not be any countable rollovers, but because part was rolled back to the TIRA, that portion counts as a rollover. Therefore, the one rollover limit has not been exceeded by these transactions.

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