IRA ROLLOVER

If have:

1 retirement plan w/ company 1 and received 1 distribution with 2022 1099-r,

plus IRA in portfolio investments under one financial advisor with several 2022 1099-r issued with:

1 1099-r company 2 (under 1 payer EIN) with several different funds listed with different fund-acct numbers and multiple distributions 2022 from each fund and

a second set of of multiple 1099-r company 3 forms (each with same payer EIN that is not same as company 2 EIN) and each with a different fund name & account number with multiple distributions 2022 from each fund; and

There were no non-taxable rollovers made one year prior to August 2nd 2022 and

On August 2nd 2022 distributions made from both company 2 funds and company 3 funds, w/ subsequent rollover contributions to both prior to end of 60 day rollover period – do all of these August 2nd fund distributions qualify for the “one nontaxable 60-day rollover within one year period” and eligible for non-taxable rollover treatment? Not sure criteria for determining how many IRA accounts in this situation for one rollover per 12 month limitation?



Only one IRA distribution can be rolled over within a 12 month period. This only applies to IRA distributions, so you can ignore any rollovers from non IRA plan distributions. You can also treat distributions made on the same date as one distribution even if you received multiple 1099R forms, but I would keep documentation showing these distributions were done on the same day. The 1099R forms do not show dates, that would be shown on your account statements. Conversely, if you only had one account and took distributions on different dates, they could be combined on a single 1099R, but you could still roll over only one of them.

so for the 1 per 12 month IRA to IRA rollover limitation the IRA funds held under the single investment advisor can be treated as one IRA account even if invested with 2 different companies and getting 2 different sets of 1099r forms reported under different company EIN as long as the distributions made same day?  If you have an IRA at ABC company and also one at XYZ company and you make a distribution from each on the same day, I thought you could only do a rollover on 1 of these distributions, not both?

  • If there are two different EINs and therefore two different payers, it implies that the distributions were from two separate accounts.  Assuming that both of these are from IRAs and that the distributions that occurred within 12 month of each other, only one of these distributions is permitted to have been rolled over.  The fact that the distributions occurred on the same day is irrelevant.
  • Alan-iracritic’s reply refers to the fact that some payers (Vanguard comes to mind) issue a separate Form 1099-R for each investment distributed despite the investments being held in a single IRA account and being distributed simultaneously.  In such a case the payer would be the same, these Forms 1099-R would have the same EIN and would represent a single distribution.

Funds should always be moved by direct transfers to avoid these risks, particularly when there are multiple IRA accounts. While the one rollover limit is mostly enforced by IRA custodians, these same custodians seldom warn a client about this restriction when they request distributions. If the financial advisor knew about these distributions, they also should have warned the taxpayer about 60 day rollovers.

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