In Announcement 2014-15, the Internal Revenue Service restated its position on the number of IRA rollovers permitted in a single year. The U.S. Tax Court, in Bobrow v. Comissioner, T.C. Memo 2014-21, reviewed the statutory rule that only one IRA rollover is permitted in a single twelve month period, deciding that all IRAs of an individual are aggregated in determining if that rule has been broken. This was a surprise to many, because the IRS publication on IRAs, Publication 590, states that the rule is applied on an IRA by IRA basis. Because of this change in position, the Announcement stated that the IRS would not apply the new interpretation of the rule to rollovers involving an IRA distribution occurring before January 1, 2015. These rules do not apply to direct custodian to custodian IRA transfers, because they are not considered rollovers.
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