Under prior IRS rules, a rollover on day 61 was incorrect and had to be self-corrected or an expensive time consuming private letter ruling process had to be followed by the taxpayer to obtain relief from the IRS. In either case, the taxpayer was looking at extreme financial and negative emotional consequences.
Rev Proc 2016-47: Self-Certification Of Late Rollover Contribution With IRS Model Letter
Under the new Rev Proc 2016-47, instead of being required to request a private letter ruling to receive a hardship waiver for a late 60-day IRA rollover , individuals will be able to “self-certify” to their financial institution that the rollover they’re making complies with the rollover requirements, even if it doesn’t otherwise meet the 60-day rollover period. Notably, though, if the taxpayer has already requested relief from the IRS for a rollover and been denied, these new self-certification provisions cannot be used to obtain relief.
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