Back in March, the IRS announced that an individual can do only one rollover from one IRA to another in 365-day period, noting that the rule wouldn't apply before Jan. 1, 2015.
The regulation only applies to rollovers from one IRA to another, as well as one Roth IRA to another. Rollovers out of retirement plans and Roth conversions aren't covered under this rule.
The latest announcement from the IRS provides additional clarity on the timing and application of the regulation. For one thing, the agency confirmed that the rule will take effect on Jan. 1, putting to rest concerns that rollovers made anytime in 2014 might be subject to the regulation.
Further, the IRS's announcement clarifies that the rule applies to all of a given individual's accounts. Previously, some people thought that the rules applied individually to IRAs and Roth IRAs, hence permitting one IRA-to-IRA rollover and one Roth-IRA-to-Roth-IRA rollover. That's not the case, you get only one of these transactions per 365-day period.
Clients who are moving an IRA and who end up getting a check need to ensure that the check is being made to the receiving IRA and not to them personally. A check made directly to the client is considered a rollover, and the rules will apply. A check made to an institution, however, is considered a trustee-to-trustee transfer.
Naturally, with all tax law changes, you should consult your CPA to see how such a change may impact you directly.