With the release of Revenue Procedure 2016-47 in April of 2016, clients now have a new way of avoiding the complications of a missed 60–day rollover period. Clients can now self-certify their eligibility for an extension if certain requirements are met, eliminating the need for IRS preapproval. Therefore, planners need to explain to clients the events that could trigger the self-certification process and, perhaps more importantly, identify specific requirements that could arise under each option for self-certification. This paper examines private letter rulings regarding 60–day waivers to clarify how IRS thinking will apply to a client’s specific situation. After studying the various circumstances under which waivers were granted (and perhaps more importantly, denied), a clear pattern begins to emerge. By applying these historical trends to a client’s current situation, planners can help their clients identify situations in which they may receive a waiver for the 60–day rollover rule.
Kevin Tacchino is currently a master of taxation and financial planning candidate at Widener University. He also works as an associate business consultant for the Widener University Small Business Development Center, where he helps clients tackle a variety of financial issues. He attended Elizabethtown College, where he earned his bachelor of science in business administration with a double concentration in finance and economics.