The IRS, in Announcement 2014-15, has indicated it will follow the recent Tax Court decision in Bobrow v. Commissioner, which held that a taxpayer may make only one tax-free, 60-day rollover between IRAs within each 12-month period, regardless of how many IRAs he or she maintains. However, the IRS will not apply this new interpretation to any rollover that involves an IRA distribution occurring before January 1, 2015.
http://www.irs.gov/pub/irs-drop/a-14-15.pdf
via Broadridge
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