Sunday, March 23, 2014
The IRS has recently issued Announcement 2014-15, stating that it will withdraw Proposed Regulation 1.408-4(b)(4)(ii) and Publication 590, which would limit IRA rollovers on an IRA-by-IRA basis, and instead will now interpret IRC Section 408(d)(3)(B) as limiting IRA rollovers on an aggregate basis.
The Announcement follows the interpretation set forth in the Tax Court's opinion in Bobrow v. Commissioner, T.C. Memo 2014-21. However, in order to allow IRA trustees to make changes in the processing of IRA rollovers, the IRS will not apply the new interpretation until January 1, 2015. The IRS also stated that the limitation will not affect the ability of an IRA owner to transfer funds from one IRA trustee directly to another.
See Announcement 2014-15, March 20, 2014.
Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.