IRA to Bank to Roth

Hello-

Client took an IRA distribution from two separate IRAs as a normal distribution to their bank account. They are wanting to move both distributions into their Roth as a conversion.
1. Can they do this with both distributions?
2. Does it have to come from the same bank account or can money be transferred into the Roth from their individual TOD investment account?
3. Do neither of these distributions count as an indirect rollover? For example, she could do an indirect rollover next month if she wanted and not run afoul of the once in 12mo rule?

Thank you!



  1. Yes, conversions are not subject to the one rollover per 12 month limitation.
  2. It can come from any account, but the Roth custodian must be told these are conversions.
  3. These are both indirect (60 day) rollovers, but they are not subject to the one rollover limit. Therefore, next month a TIRA to TIRA or Roth IRA to Roth IRA rollover could be done. 
  4. In other words, conversions do not count and neither does any rollovers between IRAs and qualified plans.


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