The IRS has issued Announcement 2014-15, which provides that the IRS will be following the decision in Borrow v. Commissioner, TC Memo 2014-21. That case holds that the one-rollover-per-year rule under Section 408(d)(3)(B) applies to all of a taxpayer’s IRAs, not to each IRA separately. This is a change in the IRS position, and the IRS has indicated that it will be rewriting Publication 590 to reflect this change. This means that the one-rollover-per-year rule (applied on a 12-month basis, not a calendar-year basis) is now going to apply on a taxpayer basis, rather than an IRA by IRA basis. Note that there is no limit on the number of direct transfers. The IRS has announced that it will not apply the new rule to any rollover that involves an IRA distribution occurring before January 1, 2015.