In the past, there has been no exception to the rule that a taxpayer must complete the rollover of an eligible rollover distribution within 60 days in order to avoid current income taxation on the distribution. In Revenue Procedure 2003-16 the IRS sets forth procedures for taxpayers to apply to the Service for a waiver of the 60-day rollover requirement and provides for an automatic waiver of the 60-day rollover rule in certain circumstances. The revenue procedure is effective January 27, 2003, for distributions that are made after December 31, 2001.
If the financial institution receiving the rollover causes the failure the complete the rollover in 60 days, the taxpayer is entitled to an automatic waiver of the 60-day rollover rule and need not apply to the IRS for approval. Specifically, the automatic waiver is available if a financial institution receives funds on behalf of a taxpayer before the end of the 60-day rollover period and the taxpayer follows all of the procedures
