60-Day Rollover
A 60-day rollover is a method of moving retirement-plan funds where the distribution is paid to the participant, who then redeposits the full amount within 60 calendar days into another eligible retirement account. Limited to once per 12-month period across ALL IRAs owned by the taxpayer (Bobrow v. Commissioner, 142 T.C. 13 (2014)).
Until 2014, custodians and most tax practitioners interpreted the once-per-12-months rule as per-IRA — each separate IRA could do its own 60-day rollover annually. The Tax Court's Bobrow decision rejected that interpretation: the rule is taxpayer-wide, not per-account. Any second 60-day rollover within 12 months of a prior one is a fully taxable distribution, and the redeposit becomes an excess contribution. The IRS adopted the Bobrow rule effective January 1, 2015 (Announcement 2014-32), and it has been the operative rule ever since.
The 60-day clock begins on the date the participant receives the distribution. There are no business-day extensions; weekends and holidays count. Day 60 is the last day for redeposit; day 61 is too late. The IRS has authority under §402(c)(3)(B) to waive the 60-day deadline in cases of casualty, disaster, or 'other events beyond the reasonable control' of the participant — the waiver is granted via private letter ruling and is non-trivial to obtain. SECURE 2.0 added a self-certification path under §304 for waivers in narrow circumstances (mistaken redirected check, unable to access account due to natural disaster).
For practical purposes, the 60-day rollover should be the rollover-method-of-last-resort. Trustee-to-trustee transfers (also called direct rollovers) are unlimited in frequency, do not require receipt by the participant, and don't reset the 12-month clock. The 60-day method is only useful in narrow scenarios — e.g., needing temporary cash access during the rollover period (a costly form of short-term financing). Even then, the risks (missed deadline, mandatory 20% withholding on distributions from qualified plans) usually outweigh the convenience.
Synthetic households should carry rollover-history flags so that subsequent 60-day rollovers correctly trigger the taxable-distribution path. The data should distinguish trustee-to-trustee transfers (unlimited, not subject to the rule) from 60-day rollovers (subject). For households with multiple IRAs, the once-per-12-months rule applies across the entire IRA portfolio — engines that test per-IRA will pass cases the IRS would treat as taxable.
Common pitfalls
- Treating the once-per-12-months rule as per-IRA — Bobrow rejected this interpretation in 2014 and the IRS now enforces it taxpayer-wide.
- Forgetting the mandatory 20% withholding on 60-day rollovers from qualified plans (401(k) etc.) — the participant must redeposit the FULL pre-withholding amount or have the difference treated as an early withdrawal.
- Relying on the IRS automatic-waiver options for missed deadlines — most automatic waivers fail; a private letter ruling is usually required.
- Counting the 60 days from the wrong date — the clock starts on receipt, not on the distribution-issue date.
Examples
Participant requests $50,000 from 401(k) as a 60-day rollover. Plan distributes $40,000 (after mandatory 20% withholding on the gross). Participant must redeposit $50,000 to qualify the entire distribution as a rollover; the $10,000 withheld must be made up from other funds. Failure to redeposit the full $50,000 means the unrecovered portion is treated as an early withdrawal — taxable plus 10% penalty if under 59½.