A $20,000 distribution from IRA-1 is received on October 16, 2026 and deposited into IRA-2 on December 10, 2026, day 55 of the 60 the Internal Revenue Code allows. On February 1, 2027, the owner takes $20,000 out of IRA-3 and plans to redeposit it the same way. The calendar year has turned, so the one-rollover-per-year limit looks reset. It is not: the October 16, 2026 receipt sits inside the 1-year period ending February 1, 2027.
The mistake is easy because one limit is stated in several units. The Code uses a 1-year period ending on the day of a receipt. The IRS rule page uses a 12-month period. Publication 590-A uses a 1-year period beginning on the date of receipt, then illustrates it with an example dated January 1 that reads like a calendar-year rule. The Treasury regulation still prints a 3-year period for taxable years through 1977.
Several Units for One Limit
The IRS page on the IRA one-rollover-per-year rule opens with this sentence: “Beginning in 2015, you can make only one rollover from an IRA to another (or the same) IRA in any 12-month period, regardless of the number of IRAs you own (Announcement 2014-15 and Announcement 2014-32).” Further down, the same page uses the preceding 1-year period for a 2014 Tax Court decision and the preceding 12 months for the tax consequence.
IRS Publication 590-A (2025) fixes where its 1-year period starts: “The 1-year period begins on the date you receive the IRA distribution, not on the date you roll it over into an IRA.” That settles the anchor. The unit stays open for a reader who moves on to its worked example, which speaks in calendar years. A calendar year and a 1-year period match only when the first receipt lands on January 1, one day in 365.
The Code Counts Backward From the Second Receipt
Section 408(d)(3) of the Code, read in the U.S. Code text of 26 U.S.C. 408 on GovInfo, has nine subparagraphs, (A) through (I). Subparagraph (A) creates rollover treatment in two clauses. Clause (i), the IRA-to-IRA branch, applies when:
“the entire amount received (including money and any other property) is paid into an individual retirement account or individual retirement annuity (other than an endowment contract) for the benefit of such individual not later than the 60th day after the day on which he receives the payment or distribution; or”
Clause (ii) covers a deposit into an eligible retirement plan by the same 60th day, capped at the portion of the amount that would be includible in gross income; the flush text points that term to clauses (iii) through (vi) of section 402(c)(8)(B).
Subparagraph (B), headed Limitation, is the entire one-rollover rule:
“This paragraph does not apply to any amount described in subparagraph (A)(i) received by an individual from an individual retirement account or individual retirement annuity if at any time during the 1-year period ending on the day of such receipt such individual received any other amount described in that subparagraph from an individual retirement account or an individual retirement annuity which was not includible in his gross income because of the application of this paragraph.”
Four things follow. The period is anchored on the day the second distribution is received and runs backward. The earlier event it looks for is also a receipt. That earlier amount counts only if the rollover paragraph kept it out of gross income, so a distribution that was simply taxed starts nothing. And deposit dates appear nowhere in (B); they matter only for the 60-day test in (A).
In the opening example, the 1-year period ending on February 1, 2027 reaches back to early February 2026 and contains October 16, 2026. The second $20,000 loses rollover treatment whatever day it is redeposited.
The rest are headed (C) Denial of rollover treatment for inherited accounts, etc.; (D) Partial rollovers permitted; (E) Denial of rollover treatment for required distributions; (F) Frozen deposits; (G) Simple retirement accounts; (H) Application of section 72; and (I) Waiver of 60-day requirement. Apart from (C)’s spouse test, this article relies on (C) through (H) only for their headings.
Per Account or Per Person: The 2015 Switch
The account was the first variable, and the IRS changed its reading of it in 2014. The rule page gives the history: “Proposed Treasury Regulation Section 1.408-4(b)(4)(ii), published in 1981, and IRS Publication 590-A, Contributions to Individual Retirement Arrangements (IRAs) interpreted this limitation as applying on an IRA-by-IRA basis, meaning a rollover from one IRA to another would not affect a rollover involving other IRAs of the same individual.” The next sentence reverses it: “However, the Tax Court held in 2014 that you can’t make a non-taxable rollover from one IRA to another if you have already made a rollover from any of your IRAs in the preceding 1-year period (Bobrow v. Commissioner, T.C. Memo. 2014-21).”
The current rule aggregates: “The limit will apply by aggregating all of an individual’s IRAs, including SEP and SIMPLE IRAs as well as traditional and Roth IRAs, effectively treating them as one IRA for purposes of the limit.” Publication 590-A’s version of that sentence lists only traditional, Roth, or SIMPLE IRAs and leaves out SEP.
The eCFR text of 26 CFR 1.408-4, up to date as of October 14, 2026, has seven lettered paragraphs, (a) through (g). Paragraph (b), Rollover contribution, has four subparagraphs: (b)(1) To individual retirement arrangement, (b)(2) To qualified plan, (b)(3) To section 403(b) contract, reserved, and (b)(4) Frequency limitation. Clause (i) of (b)(4) reads:
“For taxable years beginning on or before December 31, 1977, paragraph (b)(1) of this section does not apply to any amount received by an individual from an individual retirement account, annuity or bond if at any time during the 3-year period ending on the day of receipt, the individual received any other amount from an individual retirement account, annuity or bond which was not includible in his gross income because of the application of paragraph (b)(1) of this section.”
Clause (ii) reads, in full, [Reserved]. That is the number the IRS page gives for the 1981 proposed per-IRA rule; the eCFR shows it as a reserved slot, not rule text. The 1-year rule in force comes from (B) of the statute, read the way the IRS page reports the Tax Court read it.
The Publication Reads Two Ways in One Section
Publication 590-A carries both readings. Its paragraph headed Waiting period between rollovers still speaks account by account: “Generally, if you make a tax-free rollover of any part of a distribution from a traditional IRA, you can’t, within a 1-year period, make a tax-free rollover of any later distribution from that same IRA.” It continues: “You also can’t make a tax-free rollover of any amount distributed, within the same 1-year period, from the IRA into which you made the tax-free rollover.”
Read alone, those sentences block only the source IRA and the receiving IRA. The first example corrects that: with IRA-1 rolled into a new IRA-3 in 2025, the rollover “prevents you from making a tax-free rollover from IRA-2 into any other traditional IRA.” The example under Application of one-rollover-per-year limitation is the one that misleads on time:
“On January 1, 2026, you took a distribution from IRA-1 and rolled it over into IRA-2 on the same day. For 2026, you can’t roll over any other 2026 IRA distribution, including a rollover distribution involving IRA-3.”
That example is correct, because a 1-year period beginning January 1, 2026 ends December 31, 2026; in that one case the calendar year and the 1-year period are the same 365 days. The IRS rule page uses the same device with a distribution on January 1, 2015. A reader who generalizes from either example to one rollover per calendar year gets the opening case wrong.
Move the first receipt to October 16, 2026 and the two units split. A calendar-year reading blocks 77 days, October 16 through December 31, 2026. The 1-year period that begins on the date of receipt blocks 365 days, October 16, 2026 through October 15, 2027. The second receipt on February 1, 2027 is outside the first window and inside the second.
Counting from the December 10, 2026 redeposit instead moves the block to December 9, 2027, 55 days past the true end. That error is cautious; the opposite one is not. A second distribution received on September 20, 2027 and redeposited on November 5, 2027, day 46 of its own 60, is blocked, because the receipt falls inside the period and (B) counts receipts. Counting conventions could differ only on the anniversary itself; a receipt on October 17, 2027 is outside the period on any count.
Sixty Days Is a Separate Clock
The 60-day requirement in (A) also runs from receipt. Publication 590-A: “You must generally make the rollover contribution by the 60th day after the day you receive the distribution from your traditional IRA or your employer's plan.” Its example fixes the arithmetic: “To postpone including the distribution in your income, you must complete the rollover by August 29, 2025, the 60th day following June 30.” For a receipt on October 16, 2026, day 60 is December 15, 2026, so the December 10 deposit, on day 55, had five days to spare.
This clock also ignores the calendar year: “These amounts are taxable in the year distributed, even if the 60-day period expires in the next year.”
The 60 days can be stretched, and the statute’s waiver names (A) and (D), not (B). Subparagraph (I) reads: “The Secretary may waive the 60-day requirement under subparagraphs (A) and (D) where the failure to waive such requirement would be against equity or good conscience, including casualty, disaster, or other events beyond the reasonable control of the individual subject to such requirement.” Publication 590-A lists three routes: an automatic waiver, self-certification, and a private letter ruling.
The automatic waiver needs five conditions together: the institution receives the funds before the 60-day period ends; the owner followed its deposit procedures within the period; the funds missed the period solely through the institution’s error; they are deposited within 1 year from the beginning of the 60-day period; and the deposit would otherwise have been a valid rollover. Self-certification under Revenue Procedure 2020-46 carries no IRS fee, but it is not an IRS waiver, and an audit can still reject it.
Frozen deposits get two special rules. “The period during which the amount is a frozen deposit isn’t counted in the 60-day period.” And “The 60-day period can’t end earlier than 10 days after the deposit is no longer frozen.” A deposit is frozen when the institution is bankrupt or insolvent, or the state restricts withdrawals for that reason. None of these passages refers to the 1-year period in (B); the 1 year in the automatic waiver is a separate deadline.
What a Blocked Second Rollover Costs
The IRS rule page sets out the result: “Beginning in 2015, if you receive a distribution from an IRA of previously untaxed amounts: you must include the amounts in gross income if you made an IRA-to-IRA rollover in the preceding 12 months (unless the transition rule above applies), and you may be subject to the 10% early withdrawal tax on the amounts you include in gross income.” It continues: “Additionally, if you pay the distributed amounts into another (or the same) IRA, the amounts may be: treated as an excess contribution, and taxed at 6% per year as long as they remain in the IRA.”
In the opening example, the second $20,000, if previously untaxed, goes into 2027 gross income. Where the 10% early withdrawal tax applies, it adds $2,000. If the $20,000 goes back into an IRA anyway, the 6% tax can be $1,200 for each year it stays, or $3,600 over three years.
The transition rule in that sentence is history: “This transition rule applies only to 2014 distributions and only if different IRAs are involved.”
What Would Invalidate This
The statute was read in the 2021 main edition of the U.S. Code on GovInfo; a later amendment to 26 U.S.C. 408(d)(3) was not checked. The Tax Court opinion, the two 2014 IRS announcements, Revenue Procedure 2020-46, and Revenue Ruling 78-406 were not read directly; what is said about them here comes from the IRS rule page and Publication 590-A (2025). Three passages of the publication’s waiver section were not retrieved: the ruling fee, the factors the IRS weighs, and the amount that can be deposited.
Where This Doesn't Apply
Transfers that are not rollovers fall outside the limit; the IRS rule page treats a direct transfer between IRA trustees as not a rollover, citing Revenue Ruling 78-406. Publication 590-A adds conversions: “However, trustee-to-trustee transfers between IRAs aren’t limited and rollovers from traditional IRAs to Roth IRAs (conversions) aren’t limited.” Roth-to-Roth rollovers still count, and Roth accounts carry a separate clock, covered in how the Roth five-year rule splits into two clocks.
The limit in (B) is written about amounts described in (A)(i), received from an individual retirement account or annuity. By those words, a deposit under (A)(ii) into an eligible retirement plan is not the amount (B) disqualifies, and a distribution from a workplace plan is not received from an IRA.
Publication 590-A adds a two-condition exception: a distribution made by the Federal Deposit Insurance Corporation as receiver of a failed institution is not treated as a rollover for the limit if neither the institution nor the depositor initiated it, and no financial institution has assumed the failed institution’s IRAs.
Subparagraphs (E) and (C) deny rollover treatment to required distributions and inherited accounts, but (C)’s definition of inherited leaves out an account acquired by a surviving spouse, so (C) does not lift a spouse’s rollover out of the 1-year period. First-distribution timing is covered in what deferring a first RMD to April 1 does to the second year. The 3-year period in 26 CFR 1.408-4(b)(4)(i) applies only to taxable years beginning on or before December 31, 1977.
Numbers to Re-check
- The receipt date. Both clocks run from receipt; an October 16, 2026 receipt puts day 60 on December 15, 2026.
- 365 days, not 77. The 1-year period from that receipt runs through October 15, 2027; October 17, 2027 is outside it on any count.
- The second distribution’s receipt. A receipt on September 20, 2027 is inside the period even if the deposit lands on November 5, 2027.
- Every IRA the owner holds. The IRS page names SEP, SIMPLE, traditional, and Roth IRAs.
- Waiver and extension deadlines. 1 year from the start of the 60-day period for an automatic waiver; 10 days after a frozen deposit is released.
- The cost. On a blocked $20,000 rollover: $2,000 where the 10% tax applies, and $1,200 a year at 6% while it sits in an IRA.
- The edition. The examples quoted here come from Publication 590-A (2025); a later edition can move their dates without changing (B).
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