Hi Alan. Thanks for your reply. I was referring to your statement that “The one rollover limit does not apply.” My apologies for the lack of clarity.
In Notice 2009-82, relating to the 2009 RMD waiver the IRS stated
“Rollover relief for IRAs. In the case of IRA owners who have already received distributions of 2009 RMDs in 2009, the Service, under the authority of § 408(d)(3)(I), is hereby extending the 60-day rollover period for any such distribution so that it ends no earlier than November 30, 2009. However, because of the one-rollover-per-year rule in § 408(d)(3), which was unchanged by WRERA, no more than one distribution from an IRA in 2009 will be eligible for this rollover relief.”
Based on this statement, it appears that as of now, only one corona virus distribution can be rolled back. Also note that the wording reflects that the IRS interpreted the one-year rule differently at that time. The one-year rule applied separately to each IRA rather than to all the owner’s traditional IRAs.
I agree that the IRS will issue additional guidance later this year.
Thanks for your time.