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Avery Flores

IRA Technicality Question: Are "Same trustee transfers" considered "Trustee-to-trustee transfers" for the one-rollover-per-year rule?

I'm trying to organize my retirement accounts and have run into a confusing IRS technicality that I hope someone can help clarify. I currently have several IRA accounts all held at Vanguard, and I want to consolidate/reorganize them to simplify my investment strategy. According to the IRS, there's this one-rollover-per-year rule, but with an exception for trustee-to-trustee transfers. In Announcement 2014-15, the IRS states: > These actions by the IRS will not affect the ability of an IRA owner to transfer funds from one IRA trustee directly to another, because such a transfer is not a rollover and, therefore, is not subject to the one-rollover-per-year limitation of § 408(d)(3)(B). Here's what I'm confused about: If I'm moving money between IRA accounts that are all under the same trustee (Vanguard), is that still considered a "trustee-to-trustee transfer" even though it's the same trustee? Or would these internal transfers somehow count against my one-rollover-per-year limit? I won't have direct access to the funds at any point, so it's not a 60-day rollover situation where I personally receive a check. But I'm worried about accidentally triggering this rule and dealing with tax headaches. Any insights would be greatly appreciated!

You're in the clear! What you're describing is actually an internal transfer or reallocation within the same financial institution, not a rollover at all. The one-rollover-per-year rule specifically applies to situations where you take possession of the funds (receiving a check made out to you) and then have 60 days to redeposit those funds into another IRA. That's a true "rollover" in IRS terminology. When you move money between IRA accounts at the same institution (Vanguard in your case), you're just changing which account holds the assets - the trustee never changes, and you never take possession of the funds. These transfers don't count toward your one-rollover-per-year limit. The same applies to direct trustee-to-trustee transfers (like moving an IRA from Vanguard to Fidelity directly). These also don't count toward the limit because you never receive the money. The only time you need to worry about the one-rollover-per-year rule is if you physically receive a distribution check made out to you personally, which doesn't sound like what you're planning to do.

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Thanks for the explanation! Just to double check - does this also apply if I'm changing the type of IRA? Like if I have a Traditional IRA and a Roth IRA both at Vanguard, and I want to move some of the Traditional IRA money to the Roth, would that still be considered an internal transfer? Or would that be different because I'd owe taxes on the conversion?

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Moving money from a Traditional IRA to a Roth IRA is actually a conversion, not a transfer or rollover. That's a completely different transaction type and has its own set of rules. A Roth conversion is not subject to the one-rollover-per-year rule. You can do as many Roth conversions as you want in a year. However, you're correct that you'll owe taxes on the converted amount since you're moving pre-tax money (Traditional IRA) to after-tax money (Roth IRA).

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Just wanted to share my experience with this exact issue! I was reorganizing my retirement accounts last year and was getting super confused about all these IRS rules. Then I found this amazing service called taxr.ai (https://taxr.ai) that helped me figure everything out. I uploaded a PDF of my account statements and some IRS notices I had, and the AI analyzed everything and gave me clear guidance on my specific situation. It explained that transfers between accounts at the same institution wouldn't trigger the rollover limitation, and even helped me understand which specific form codes to look for on my statements to confirm everything was processed correctly. Saved me from having to spend hours on the phone with both my financial institution and the IRS! Super easy to use too - way less stressful than trying to parse IRS language on my own.

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That sounds interesting. Did you have to pay for it? And how detailed was the guidance - like did it just give generic advice or did it actually look at your specific accounts and circumstances?

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I'm always skeptical of these AI tools for tax stuff. How do you know it's giving accurate information? The IRS rules are so complex and always changing. Did you verify what it told you with a human tax professional?

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The first level of service is completely free - that's what I used initially just to get clarity on my rollover question. They do have paid options for more complex situations, but I didn't need those. The guidance was surprisingly specific to my situation. I uploaded my account statements and it identified the exact accounts I had, recognized they were all at the same institution, and provided clear guidance based on that specific setup. It wasn't just generic advice - it referenced my actual holdings and account structure. I actually did double-check with my accountant later, and he confirmed everything taxr.ai told me was correct. He said the analysis was spot-on and explained that the AI is trained on the actual tax code and IRS publications, so it's working from the official rules. The nice thing is it translates all that complex tax jargon into plain English explanations.

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I tried out taxr.ai after seeing it mentioned here, and wow - wish I'd known about this sooner! I was in a similar situation with multiple IRAs at Fidelity that I wanted to consolidate. I uploaded my statements and some past tax returns, and it immediately identified that what I wanted to do was an internal transfer, not a rollover. It explained that these transfers wouldn't count toward the one-per-year limit and even showed me exactly what forms to expect from Fidelity confirming the transfers. The best part was it looked at my specific accounts and noticed I had some non-deductible contributions in one of my Traditional IRAs and warned me about potential pro-rata rule implications I hadn't even considered! Saved me from what could have been a major tax headache. Definitely my new go-to resource for any tax questions - so much easier than wading through IRS publications.

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If you're having trouble getting clear answers about these IRA transfers, you might want to try Claimyr (https://claimyr.com). I was in a similar situation last year with some complex IRA questions that my financial advisor couldn't clearly answer. After spending hours trying to get through to the IRS with no luck, I found Claimyr. They got me connected to an actual IRS agent in about 20 minutes when I had been trying for days on my own! You can see how it works in this video: https://youtu.be/_kiP6q8DX5c The IRS agent I spoke with confirmed that transfers between accounts at the same institution are not subject to the one-rollover-per-year rule. She also walked me through exactly how these would be reported on my tax forms so I wouldn't have any issues. Honestly saved me so much stress and uncertainty.

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How does this actually work? Do they just call the IRS for you or something? I don't get it.

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Yeah right. Nothing gets you through to the IRS faster. I've literally waited on hold for 3+ hours before. If this actually worked, everyone would be using it. Sounds like a scam to me.

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It's not that they call the IRS for you - they use technology to navigate the IRS phone system and wait on hold in your place. When they finally reach an agent, you get a call to connect you directly. The reason it works is they've figured out the best times to call and how to navigate the phone tree efficiently. Plus they're constantly connected to the IRS lines throughout the day, so they can get you in queue at optimal times. When I tried on my own, I kept getting the "call volume too high" message and couldn't even get into the hold queue. I was super skeptical too! I had spent nearly a week trying to get through on my own with no luck. But I was desperate for answers about my IRA situation before making any moves, so I gave it a shot. Was honestly shocked when I got a call back saying an agent was on the line. The fee was totally worth it to finally get clear, authoritative answers directly from the IRS.

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I have to eat my words and apologize to @18. After dismissing Claimyr as a likely scam, I decided to try it myself since I've been trying to reach the IRS for weeks about an IRA rollover issue. I'm still in shock - I got connected to an actual IRS agent in about 25 minutes! I've literally never been able to get through in less than 2 hours on my own, and most times I just get the "call volume too high" message. The agent confirmed that transfers between IRA accounts at the same financial institution don't count as rollovers for the one-per-year limit. She also explained exactly how these would show up on my tax forms so I could verify everything was processed correctly. Seriously one of the most useful services I've found. If you need answers directly from the IRS about anything tax-related, especially these confusing rollover rules, it's absolutely worth it.

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One thing no one has mentioned yet is that you should check with Vanguard directly about their internal process for these transfers. While it's true that same-trustee transfers don't count toward your one-rollover-per-year limit, different financial institutions have different internal procedures for handling these moves. Some might process it as a true internal transfer, while others might actually process it as a distribution and contribution even though you never touch the money. I had this exact issue with Fidelity a couple years ago. What I thought was a simple internal transfer between two IRAs ended up being processed as a distribution and contribution, which generated a 1099-R and 5498. It didn't ultimately impact my taxes since it was still handled correctly, but it created some confusion when I got those forms. Just call Vanguard's customer service to confirm exactly how they'll process the transfer and what forms you can expect to receive for tax reporting.

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That's a really good point I hadn't considered. I assumed all transfers within the same institution would be processed the same way, but I guess that's not necessarily true. I'll definitely call Vanguard before proceeding with anything. Would you happen to know if there's specific terminology I should use when talking to them to make sure we're on the same page?

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When you call Vanguard, specifically ask them how they "code" internal transfers between IRAs and what tax forms you'll receive as a result. You want to hear that it will be processed as an "internal transfer" or "trustee-to-trustee transfer" rather than as a "distribution and contribution." Also ask if the transaction will generate a 1099-R or 5498 form. If they say it will generate these forms, that suggests they're handling it as a distribution and contribution, which could potentially trigger the one-rollover-per-year rule depending on how it's coded. If you want to be super thorough, ask them what distribution code would appear in Box 7 of the 1099-R if one is generated. For a direct trustee-to-trustee transfer, it should be coded as "G" which indicates it's not reportable for the one-rollover-per-year limitation.

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Just to add some clarity here - I work in financial services (not a tax professional though!) and deal with this frequently. The term "same-trustee transfer" is sometimes used in the industry, but the IRS generally just considers these as account-to-account transfers or internal transfers. They're not rollovers at all in IRS terminology. The one-rollover-per-year rule only applies when: 1) You take actual possession of the funds (receive a check in your name) 2) You redeposit those funds within 60 days What you're describing is neither a rollover nor a trustee-to-trustee transfer in the technical sense. It's simply an internal administrative change within the same institution. These have no limit and don't trigger any tax reporting events. Most major institutions like Vanguard have specific forms for these internal transfers to ensure they're processed correctly and don't trigger unnecessary tax reporting.

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This makes sense, but just to play devil's advocate - why would the IRS create this distinction between same-trustee transfers and trustee-to-trustee transfers? Is there a substantive difference for tax purposes?

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Great question! The IRS doesn't actually make a distinction between same-trustee transfers and trustee-to-trustee transfers for tax purposes - both are treated the same way (not subject to the one-rollover limit). The distinction is more operational than regulatory. When you move money between different institutions (like Vanguard to Fidelity), there's more paperwork, coordination between institutions, and potential for delays or errors. The receiving institution needs to verify account details, the sending institution needs to liquidate positions and send funds, etc. With same-trustee transfers, it's often just changing an account number in their system - your investments might not even need to be sold and repurchased. It's simpler administratively, but the IRS treats both scenarios identically: neither counts as a rollover because you never take possession of the funds. The key principle is that ANY direct transfer where you don't personally receive the money is exempt from the one-rollover-per-year rule, regardless of whether it's between different trustees or within the same one.

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This is really helpful information from everyone! I'm in a similar situation with multiple Vanguard accounts that I've been wanting to consolidate for months but kept hesitating because I wasn't sure about the rollover rules. Based on all the responses here, it sounds like internal transfers at the same institution are pretty straightforward and don't count toward the one-rollover limit. I especially appreciate the advice about calling Vanguard directly to confirm their process and what forms to expect. One follow-up question - does anyone know if there are any limits on how many internal transfers you can do in a year? I have four different IRA accounts at Vanguard that I'd like to consolidate into two, so I'd be doing multiple transfers. Want to make sure there aren't any other rules I should be aware of before proceeding. Thanks to everyone who shared their experiences and expertise!

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No limits on internal transfers! You can do as many as you want within the same institution in a year. The one-rollover-per-year rule only applies to situations where you personally receive the funds, which won't happen with internal transfers. Your plan to consolidate four accounts into two at Vanguard should be totally fine. Just make sure when you call them that you specify you want "internal transfers" between your IRA accounts, not rollovers. They'll handle all the paperwork and shouldn't generate any confusing tax forms since the money never leaves Vanguard's custody. The only thing to consider is if you have any non-deductible contributions in your Traditional IRAs - that could complicate things with the pro-rata rule, but that's a separate issue from the rollover limitations.

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This is such a helpful discussion! I've been dealing with a similar situation and was getting overwhelmed by all the IRS terminology. One thing I'd add based on my recent experience - when I called Fidelity about consolidating my IRAs, they actually walked me through a "dry run" of what the process would look like before I committed to anything. They explained exactly how they'd process each transfer, what forms I'd receive, and even gave me a timeline for when everything would be completed. It was really reassuring to know exactly what to expect before moving forward. The representative also confirmed that internal transfers between my IRA accounts wouldn't generate any 1099-R forms since the money never left their custody, which eliminated my biggest concern about accidentally triggering tax issues. For anyone still feeling uncertain about this, I'd definitely recommend asking your financial institution to walk you through their specific process step-by-step. It only took about 10 minutes on the phone but gave me complete confidence to move forward with my consolidation plan.

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That's excellent advice about doing a "dry run" with your financial institution! I wish I had thought of that when I was dealing with my own IRA consolidation. Having that step-by-step walkthrough would have saved me so much anxiety about potentially making a mistake. It's also really reassuring to hear that Fidelity confirmed no 1099-R forms would be generated for internal transfers. That seems to be consistent with what others have shared about Vanguard's process as well. It sounds like the major institutions have their internal transfer procedures pretty well standardized to avoid creating unnecessary tax complications for their customers. Thanks for sharing that tip - I'm sure it will be helpful for anyone else in a similar situation!

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This thread has been incredibly informative! As someone who's been putting off reorganizing my retirement accounts for way too long, reading through everyone's experiences has finally given me the confidence to move forward. I particularly appreciate the distinction that several people made about the terminology - that internal transfers within the same institution aren't technically "rollovers" at all in IRS speak, so the one-rollover-per-year rule doesn't even come into play. That makes so much more sense than trying to figure out whether same-trustee transfers count as trustee-to-trustee transfers. The advice about calling your financial institution for a "dry run" is golden. I'm definitely going to do that with my Schwab accounts before making any moves. It's such a simple step that could prevent a lot of headaches down the road. One small addition based on my own research - I've found that most major brokerages have online help articles or FAQs specifically about IRA consolidation that can be helpful to review before calling. They often include screenshots of the forms you'll need to fill out and examples of how the transfers will appear on your statements. It's nice to have that background knowledge when you're talking to a representative. Thanks to everyone who shared their experiences - this community is such a valuable resource!

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Absolutely agree about checking those online resources first! I did the same thing with my Vanguard accounts and found their IRA consolidation FAQ really helpful for understanding the process before I called. One thing I'd add - when you do call Schwab, ask them if they have any special online tools or calculators for IRA consolidation. Some institutions have really helpful digital tools that can model different consolidation scenarios and show you exactly what your new account structure would look like. Vanguard had something like this that helped me visualize which accounts to merge and which to keep separate based on my investment strategy. It's great to see so many people finally taking action on organizing their retirement accounts after reading this discussion. The peace of mind from having everything properly consolidated and understanding the rules is totally worth the small effort it takes to get it done right!

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This has been such an enlightening thread! I'm dealing with a very similar situation - multiple IRAs at Vanguard that I've been wanting to consolidate but was nervous about the tax implications. What really clicked for me reading through everyone's experiences is that these internal transfers are fundamentally different from rollovers because you never actually receive the money. The one-rollover-per-year rule is specifically designed to prevent people from using their IRA as a short-term loan by taking distributions and redepositing them multiple times. I love the suggestion about doing a "dry run" with your financial institution. That seems like such a smart way to understand exactly what will happen before committing to anything. I'm definitely going to call Vanguard and ask them to walk me through their process step by step. One question for those who have already done this - did you consolidate all your accounts at once, or did you do it gradually over time? I'm wondering if there are any advantages to spacing out the transfers versus doing everything in one go. Thanks to everyone who shared their knowledge and experiences - this community is amazing for getting real-world insights on these complex tax situations!

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