Editorial page: This is a plain-English explainer of the IRS one-rollover-per-year rule as it applies to precious metals IRAs. We do not sell coins or accounts. We are not financial or tax advisors. Consult a licensed advisor before making retirement decisions.
Last updated: August 4, 2026 · By White Metal Resources Editorial
Quick answer: The IRS allows only one indirect IRA-to-IRA rollover per taxpayer in any rolling 12-month period, aggregated across every traditional, Roth, SEP, and SIMPLE IRA you own. Direct trustee-to-trustee transfers are unlimited. Rollovers from a 401(k), 403(b), 457(b), or TSP into an IRA do not count against the limit. Roth conversions do not count either.
Short on time? The essentials
- You may make one indirect IRA-to-IRA rollover during any rolling 12-month period, not one per calendar year.
- The limit is aggregated across all your IRAs (traditional, Roth, SEP, SIMPLE), not one per account.
- Direct trustee-to-trustee transfers between IRAs are not counted, and you may do them as often as needed.
- Rollovers from a workplace plan (401(k), 403(b), 457(b), TSP) into an IRA are not counted, direct or indirect.
- Roth conversions from a traditional IRA to a Roth IRA are not counted against the limit either.
- A second indirect IRA-to-IRA rollover within 12 months is treated as a taxable distribution, even if you meet the 60-day deadline.
- The rule stems from Bobrow v. Commissioner (T.C. Memo 2014-21), adopted by IRS Announcement 2014-15 starting January 1, 2015.
- For a precious metals IRA move, the safe default is the trustee-to-trustee route, which bypasses both this limit and the 60-day rule.
Savers who move retirement money into a silver, platinum, or palladium IRA often run into a single number: one. One rollover per year. The number is real, but the details around it decide whether a routine funding step lands cleanly or triggers a tax bill.
This page walks through the rule, the exceptions, and the safe route most precious metals IRA moves use by default. Every figure and rule below traces to a primary IRS or statutory source, cited inline. The page is educational, not legal or tax advice.
What does the one-rollover-per-year rule actually say?
The IRS caps how often you may use an indirect rollover between IRAs. You may make only one indirect IRA-to-IRA rollover during any rolling 12-month period. This is not a calendar-year cap. It runs from the date the funds were received in the earlier rollover (source: IRS, IRA one-rollover-per-year rule).
The count is per taxpayer, aggregated across every IRA you own. Whether the money moved from a traditional IRA to a traditional IRA, from a Roth IRA to a Roth IRA, or across a SEP or SIMPLE IRA, all indirect rollovers land in the same bucket. A second one inside 12 months is treated as a taxable distribution.
The statute uses the words "one rollover per year" but the applied rule after 2014 is much stricter than most savers realized in the 1990s and 2000s. The change followed a single Tax Court case. Understanding that case explains why the IRS applies the rule the way it does today.
Where the rule comes from: Bobrow and Announcement 2014-15
The statutory basis sits in 26 U.S.C. section 408(d)(3)(B), which limits an individual to one rollover contribution per year "from an individual retirement account or individual retirement annuity" (source: Cornell LII, 26 U.S.C. section 408(d)(3)(B)).
For decades, the IRS applied that limit on a per-account basis. If you owned three IRAs, you could technically do one indirect rollover from each account each year. That reading was based on a long-standing IRS position, including Publication 590 through 2013.
The Tax Court disagreed. In Bobrow v. Commissioner, T.C. Memo 2014-21, decided January 28, 2014, the court held that the statute's limit applies in the aggregate, across all IRAs a taxpayer owns. The tax bill in that case was substantial, and the ruling forced the IRS to change its published guidance (source: Bobrow v. Commissioner, T.C. Memo 2014-21).
The IRS accepted the aggregate reading in Announcement 2014-15 and formally applied it starting January 1, 2015. That announcement is why every current IRS explanation of the rule uses the phrase "regardless of how many IRAs you own" (source: IRS Announcement 2014-15, PDF).
What counts against the limit and what does not
Two categories exist. Only one of them counts. The other category is unlimited by design, which is why most precious metals IRA rollovers never come near the limit at all.
| Type of move | Counts against limit? | Reason |
|---|---|---|
| Indirect IRA-to-IRA rollover (check paid to you) | Yes | Section 408(d)(3) rollover subject to the limit |
| Direct trustee-to-trustee IRA transfer | No | Not a rollover under section 408(d)(3), not counted |
| Rollover from a 401(k), 403(b), 457(b), or TSP into an IRA | No | Not an IRA-to-IRA move, direct or indirect |
| Rollover from an IRA into a 401(k) or other workplace plan | No | Not an IRA-to-IRA move |
| Roth conversion (traditional IRA to Roth IRA) | No | Treated as a conversion, not a rollover, for this rule |
| Rollover from a traditional IRA to a Roth IRA at a different custodian | No | Still treated as a conversion, not counted |
| Second indirect IRA-to-IRA rollover within 12 months | Prohibited | Treated as a taxable distribution, not a rollover |
Sources: IRS Announcement 2014-15; IRS Publication 590-A; 26 U.S.C. section 408(d)(3). Checked August 4, 2026.
The practical upshot: only the first row of the table above counts against the limit. Every other row is either unlimited or subject to a different rule set (the 60-day deadline still applies to indirect moves, and conversions have their own tax treatment).
For a walk-through of the direct vs indirect distinction and the withholding numbers attached to each, see the companion page on the direct vs indirect rollover into a silver IRA. For the difference between a rollover and a transfer, see the queued page on transfer vs rollover for a precious metals IRA.
How the aggregate rule works across your IRAs
The aggregation is the piece that trips savers most often. If you own five IRAs at four different custodians, the once-per-12-months cap still applies once, not five times. The rule follows the person, not the account.
Traditional and Roth IRAs share the same count. A rollover from a Roth IRA to a Roth IRA uses up the same annual allowance a rollover from a traditional IRA to a traditional IRA would. You cannot separate the two buckets to double up.
SEP IRAs and SIMPLE IRAs are also aggregated with traditional and Roth IRAs for this rule. A rollover from a SEP IRA at one custodian to a traditional IRA at another counts against the limit for both accounts and every other IRA you own for the next 12 months.
Inherited IRAs sit outside the count only where a non-spouse beneficiary is involved, because non-spouse inherited IRAs generally cannot be rolled over at all (they can only be transferred trustee-to-trustee). Spousal inherited IRAs treated as the surviving spouse's own IRA fall inside the count.
How the 60-day rule stacks on top
The once-per-12-months limit and the 60-day rule are separate. Both apply to the same indirect rollover. Meeting one does not excuse missing the other.
The 60-day rule gives you 60 calendar days from receipt of the distribution to redeposit the full pretax amount into a receiving IRA. Miss that deadline and the amount not redeposited becomes ordinary income, plus a 10 percent additional tax under section 72(t) if you were under 59.5 on the distribution date (source: IRS Publication 590-A).
The once-per-12-months rule adds a second failure mode. Even if you nail the 60-day deadline on both rollovers, the second one is still a taxable distribution because it exceeds the annual limit. For the mechanics of the 60-day clock in detail, see the companion page on the 60-day rollover rule and your precious metals IRA.
Consequences of breaking the limit
The IRS does not treat a second indirect IRA-to-IRA rollover in a 12-month window as an oversight. The full amount of the second rollover is treated as a distribution from the source IRA. Three tax consequences follow, and one of them only affects younger savers.
- Federal income tax on the entire second-rollover amount at your marginal rate. The distribution is added to your other income for the year and taxed as ordinary income (source: IRS Publication 590-B).
- A 10 percent additional tax under 26 U.S.C. section 72(t) if you were under 59.5 on the distribution date and no listed exception applies. This piece is layered on top of the ordinary income tax (source: IRS Topic 558, Additional Tax on Early Distributions).
- An excess contribution in the receiving IRA, because the funds that landed there did not qualify as a rollover. The excess is subject to a 6 percent excise tax per year under section 4973 until removed (source: Cornell LII, 26 U.S.C. section 4973).
State income tax may stack on top, depending on where you live. The distribution loses its tax-deferred status forever. Even if you withdraw the excess contribution from the receiving IRA later, you cannot restore the pretax character of the money that was ruled a distribution.
Why this matters for a precious metals IRA
Most savers moving money into a silver, platinum, or palladium IRA use one of two sources: a former-employer 401(k) or an existing IRA at a mainstream brokerage. The once-per-12-months rule affects the second source, not the first.
If you are rolling a 401(k), 403(b), 457(b), or TSP into a precious metals IRA, the rule is irrelevant. Workplace-plan rollovers into IRAs are not counted, whether direct or indirect. See the companion walkthrough on the 401(k) rollover to a precious metals IRA for the paperwork sequence.
If your source is an IRA at another custodian, the trustee-to-trustee transfer route sidesteps the rule entirely. The receiving custodian sends the transfer request to the source custodian, the source liquidates the position, and the cash arrives at the new IRA. No cash reaches your bank account, so no rollover clock or count applies.
Fees are a separate concern the rollover rules do not touch. Our precious metals IRA fee explainer lays out the setup, storage, and buy-sell-spread components in one place. If you are still selecting a receiving custodian, the neutral hub of precious metals IRA companies is the right starting point.
A worked example
Picture a saver, age 58, who owns three IRAs: a traditional IRA at Broker A, a Roth IRA at Broker B, and a SEP IRA left over from a former consulting business at Broker C. She wants to move some of the SEP IRA and some of the traditional IRA into a new silver IRA.
- On February 10, she takes a $30,000 indirect rollover from the SEP IRA. The check is mailed to her. She deposits it into the new silver IRA on February 22, well inside the 60-day window. This uses her one allowed indirect rollover for the rolling 12-month period ending February 10 next year.
- On July 15, she takes another indirect rollover of $20,000 from the traditional IRA, planning to redeposit it in the silver IRA. She meets the 60-day deadline again.
- The second rollover is prohibited. The $20,000 is treated as a taxable distribution from the traditional IRA for the year. At a 22 percent federal bracket, that piece triggers about $4,400 of federal income tax.
- She was 58 on the distribution date, under 59.5, so the 10 percent additional tax under section 72(t) also applies, adding about $2,000. The bill is roughly $6,400 before state tax.
- The $20,000 that landed in the silver IRA is an excess contribution. She needs to withdraw it (plus any earnings on it) by the extended due date of her tax return to avoid the 6 percent excise tax per year going forward.
Had she used a trustee-to-trustee transfer for either or both moves, none of this would apply. This is why the direct route is the safe default for precious metals IRA funding. Numbers are illustrative and use a rounded federal bracket with no state tax. Consult a licensed tax advisor for your situation.
The safe route: trustee-to-trustee transfer
The cleanest way to avoid both the once-per-12-months rule and the 60-day rule is to never trigger either. A trustee-to-trustee transfer moves cash directly from the source IRA custodian to the receiving precious metals IRA custodian. You never touch the funds (source: IRS, Rollovers of Retirement Plan and IRA Distributions).
Because no distribution is deemed to have been paid to the account holder, the IRS does not treat the move as a rollover for purposes of section 408(d)(3). It is a transfer. The one-rollover-per-year cap does not apply. The 60-day deadline does not apply. You can do as many trustee-to-trustee transfers as your custodians will process.
In practice, most receiving precious metals IRA custodians handle the transfer paperwork on your behalf once you complete their transfer authorization form. The whole process usually takes two to four weeks depending on the source custodian's outbound queue.
The other exempt route is any rollover from a qualified workplace plan into an IRA. Those moves are not counted, direct or indirect. If your source is a 401(k) or TSP, you have full flexibility on frequency for those funds specifically.
Questions answered
Is the one-rollover-per-year limit really per taxpayer, not per account?
Yes. Since January 1, 2015, the IRS has applied the limit in the aggregate across all IRAs a taxpayer owns, following the Tax Court ruling in Bobrow v. Commissioner. Owning multiple IRAs at different custodians does not give you multiple rollover allowances. The count is per person, per rolling 12-month period.
Does the limit run on a calendar year or a rolling 12 months?
Rolling 12 months. If you took an indirect IRA-to-IRA rollover on March 15, you cannot take another indirect IRA-to-IRA rollover until March 16 of the following year. Starting a new tax year does not reset the count. Watch the receipt date of the earlier distribution as the reset point.
Do trustee-to-trustee transfers count against the limit?
No. Direct trustee-to-trustee transfers between IRAs are not treated as rollovers under section 408(d)(3), so the once-per-12-months limit does not apply. You may do as many trustee-to-trustee transfers as you need. This is why most precious metals IRA funding uses the transfer route by default.
If I roll a 401(k) into an IRA, does that use up my allowed rollover?
No. A rollover from a qualified workplace plan (401(k), 403(b), 457(b), TSP) into an IRA is not an IRA-to-IRA rollover, so it is not counted against the once-per-12-months limit. This applies whether the rollover is direct (trustee to trustee) or indirect (check paid to you first).
Does a Roth conversion count against the limit?
No. A Roth conversion is treated as a conversion, not a rollover, for purposes of the once-per-12-months rule. You may do multiple Roth conversions in a single year from the same or different traditional IRAs. Conversions do carry their own tax cost, since the converted amount is added to taxable income for the year.
What happens if I accidentally take a second indirect rollover in the same year?
The second rollover is treated as a taxable distribution from the source IRA, and the amount that landed in the receiving IRA is an excess contribution. You owe ordinary income tax on the distribution, plus a 10 percent additional tax if you were under 59.5, plus a 6 percent excise tax per year on the excess contribution until removed.
Does the once-per-year rule apply separately to my traditional and Roth IRAs?
No. Traditional, Roth, SEP, and SIMPLE IRAs are all aggregated for this rule. A rollover between two Roth IRAs uses the same annual allowance as a rollover between two traditional IRAs. This is one of the most common misunderstandings. The count follows the taxpayer, not the account type.
Can I do a partial indirect rollover and leave room for another one later?
No. Any indirect rollover from an IRA in a given 12-month period uses up your allowance for that period, regardless of the amount. A $500 indirect rollover on January 10 blocks another indirect IRA-to-IRA rollover of any size until January 11 of the following year. Use trustee-to-trustee transfers for additional moves.
Sources
- IRS, IRA one-rollover-per-year rule (aggregate application, effective January 1, 2015). Checked August 4, 2026.
- IRS, Announcement 2014-15, application of one-per-year limit on IRA rollovers, PDF. Checked August 4, 2026.
- U.S. Tax Court, Bobrow v. Commissioner, T.C. Memo 2014-21 (aggregate reading of the one-rollover-per-year limit). Checked August 4, 2026.
- IRS, Publication 590-A, Contributions to Individual Retirement Arrangements (Chapter 1 covers rollovers, transfers, and the once-per-year rule). Checked August 4, 2026.
- IRS, Publication 590-B, Distributions from Individual Retirement Arrangements. Checked August 4, 2026.
- IRS, Rollovers of Retirement Plan and IRA Distributions (overview page). Checked August 4, 2026.
- IRS, Topic 558, Additional Tax on Early Distributions. Checked August 4, 2026.
- Cornell Legal Information Institute, 26 U.S.C. section 408 (IRAs, including subsection (d)(3)(B) on the rollover limit). Checked August 4, 2026.
- Cornell Legal Information Institute, 26 U.S.C. section 4973 (6 percent excise tax on excess IRA contributions). Checked August 4, 2026.
- IRS, Rollover Chart (which plans can roll into which, and how the rules differ). Checked August 4, 2026.
