60 day rollover rule

I would like some clarification on this rule. I have read the IRS regs on this, but am still not quite clear. I know beginning on January 1, 2015, a taxpayer must aggregate all of their IRA’s for purposes of this rule and when processing a distribution, and then rolling over that amount into another IRA. What I am not clear on is what if a client has for instance a Traditional annuity IRA which is assigned one IRA plan number by the custodian, and then has another IRA plan number which has multiple investment account numbers under that different IRA plan number. Even though there are two different IRA plan numbers assigned by the custodian for this one client, are both of them together “deemed” to be “one” IRA. I didn’t see where the regs really addressed this.

John Nielsen



While IRA annuities are typically held in an IRA account without other investments, it really does not matter with respect to the recent rollover rules. More IRA accounts mean more 1099R forms for which a rollover would be reported, but only if indirect 60 day rollovers are used. The answer is to always move IRA money by direct trustee transfer since these are unlimited in number and are not even reported on a 1099R. The IRS will only look at 1099R forms, so if there were two IRA accounts you could only move one of them by rollover, whereas if the accounts were combined you could move the entire account with the one permitted indirect rollover. Do you have a situation where someone received distributions in this situation and it now turns out there were two 1099R forms issued?  If so, was this within the last 60 days?



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