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401(k) Rollover to an IRA in 2026: Direct, 60-Day, Withholding

By Jorge··24 min read

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Quick Answer

As of October 22, 2026, a 401(k) can reach an IRA two ways and the tax rules treat them very differently: a direct rollover has no withholding and no 10% additional tax, while a distribution paid to you has 20% withheld by law, even if you plan to roll it over, and you have 60 days to deposit the whole amount. The withholding is 26 U.S.C. 3405(c)(1); the 60 days are 26 U.S.C. 402(c)(3)(A); IRS Publication 590-A (2025) explains both. The once-a-year limit that many guides attach to every rollover is 26 U.S.C. 408(d)(3)(B) and it covers IRA-to-IRA rollovers: Pub. 590-A says it “doesn't apply to eligible rollover distributions from an employer plan”. Required minimum distributions, hardship distributions and series of substantially equal payments cannot be rolled over at all (402(c)(4)). The trap for someone leaving a job at 55 to 59½ is that 26 U.S.C. 72(t)(3)(A) says the separation-from-service exception “shall not apply to distributions from an individual retirement plan”. In a worked example (our arithmetic), a $500,000 distribution paid to you leaves you $400,000 in cash and $100,000 to find elsewhere to roll over the full amount; if it arrived October 22, 2026, the 60th day is December 21, 2026. A late rollover can be saved by self-certification under Rev. Proc. 2020-46 (12 listed reasons, a 30-day safe harbor); a private letter ruling costs an $18,500 user fee. This is analysis of public documents, not investment, legal or tax advice.

Key Takeaways

  • Direct rollover versus a payment to you is the whole decision for the tax result. Pub. 590-A (2025) says that with a direct rollover “no tax is withheld”, and that if any part is paid to you the payer must withhold 20% of its taxable amount; Pub. 575 (2025) adds that a direct rollover has no 10% additional tax, while a payment to you can trigger it, under age 59½, on the taxable part not rolled over, including an amount equal to the tax withheld.
  • A “direct” rollover can arrive as a check. 26 CFR 1.401(a)(31)-1 Q&A-4 accepts a check handed to you if it is payable to the trustee of the receiving IRA, in the form “[Name of the trustee] as trustee of [name of the eligible retirement plan]”. A check payable to you personally is a payment to you, with 20% withheld.
  • The 60 days run from the day you receive the distribution (26 U.S.C. 402(c)(3)(A)). To roll over the full amount you must replace the withheld 20% with other money: on $500,000 that is $100,000 (our arithmetic on Pub. 575's $10,000 example).
  • The once-a-year rule is 26 U.S.C. 408(d)(3)(B) and it is about IRA distributions. For an employer plan, Pub. 590-A says you “can roll over more than one distribution from the same employer plan within a year”. It still bites later: a second 60-day IRA-to-IRA move of the same money inside 12 months is the case the rule catches, and the IRS cannot waive it.
  • Not everything in the account can be rolled. 26 U.S.C. 402(c)(4) excludes required minimum distributions, hardship distributions and series of substantially equal payments over life or 10 years or more; Pub. 590-A adds corrective distributions, deemed loan distributions, dividends on employer securities and the cost of life insurance.
  • The 10% age 55 exception for plan distributions after separation from service is not available from an IRA: 26 U.S.C. 72(t)(3)(A) says so in one sentence. At age 57 a $50,000 withdrawal costs $5,000 of additional tax from an IRA and $0 from the plan, income tax aside (our arithmetic).
  • Small balances move without your choice. Under 26 U.S.C. 401(a)(31)(B) a plan that cashes out balances up to $7,000 must send a distribution over $1,000 to an IRA if you make no election; the $7,000 replaced $5,000 under Pub. L. 117-328 section 304.

CSV · 188 rows

401(k) rollover to an IRA: rollover chart, withholding, 60-day clock and exceptions, October 2026

188 rows: the 64-cell rollover chart of Pub. 590-A (2025), what cannot be rolled over, the 20%, 60-day, $200, $1,000 and $7,000 rules, the 12 self-certification reasons of Rev. Proc. 2020-46, plan versus IRA exceptions to the 10% additional tax, Notice 2014-54 after-tax examples, FINRA rollover factors and worked examples, each with its source.

Two ways to move the money

When you leave an employer the plan must give you a written explanation of your options. Pub. 590-A (2025) says it has to arrive “no earlier than 90 days and no later than 30 days before the distribution is made”, unless you choose a shorter period after at least 30 days to decide. The choice you make on the form sets the tax result.

ItemDirect rolloverPaid to youSource
WithholdingNone on the part paid directly to the IRA trustee20% of the taxable part, required by law even if you mean to roll it overPub. 590-A (2025) Table 1-5; 26 U.S.C. 3405(c)(1)
10% additional tax (under 59½)NoneMay apply to the taxable part not rolled over, including an amount equal to the tax withheldPub. 575 (2025) Table 1
When the money counts as incomeNot until later paid out of the IRAIn the year paid, for anything not rolled over within 60 daysPub. 575 (2025) Table 1
ClockNone to meet60th day after receipt26 U.S.C. 402(c)(3)(A)
Full amount to roll overWhole balance moves, nothing to replaceGross amount, including the withheld 20%, so you add other moneyPub. 575 (2025)
Paper formForm 1099-R code GForm 1099-R with the withholding in box 4; the rollover is reported on your Form 1040Instructions for Forms 1099-R and 5498 (2026); Pub. 590-A (2025)

Source: IRS Publication 590-A (2025), Table 1-5; IRS Publication 575 (2025), Table 1; 26 U.S.C. 3405(c)(1) and 402(c)(3)(A); Instructions for Forms 1099-R and 5498 (2026), distribution code G.

A direct rollover does not need a wire. 26 CFR 1.401(a)(31)-1 Q&A-4 says “Providing the distributee with a check and instructing the distributee to deliver the check to the eligible retirement plan is a reasonable means of direct payment, provided that the check is made payable as follows”, naming the trustee “as trustee of” your IRA. If the check is made out to you, it is not a direct rollover and the 20% applies. Q&A-10 adds that the plan “is not required (but is permitted)” to split a distribution among several destinations, so ask whether it will pay one IRA and one new employer plan in the same distribution.

The 60-day clock with dates

Section 402(c)(3)(A) says the rollover is not allowed for a transfer “made after the 60th day following the day on which the distributee received the property distributed”. Counting is by calendar day, as Pub. 590-A's own example shows: received June 30, deadline August 29. The table applies the same count to five 2026 dates (our arithmetic).

Distribution received60th day (last day to deposit)What to check (our reading)
October 22, 2026December 21, 2026Both dates fall in 2026
November 16, 2026January 15, 2027The deposit may land in 2027; the distribution is still reported for 2026
December 1, 2026January 30, 2027Same: income-year reporting follows the distribution date
December 21, 2026February 19, 2027Pub. 590-A's own example treats an unrolled late-December distribution as taxable in the year distributed
December 31, 2026March 1, 2027Last day of the year; the count still starts the next day

Source: arithmetic on 26 U.S.C. 402(c)(3)(A); IRS Publication 590-A (2025), Time Limit for Making a Rollover Contribution.

Missing the date is expensive. Pub. 590-A (2025) says amounts not rolled over within 60 days must be treated as a taxable distribution, “taxable in the year distributed, even if the 60-day period expires in the next year”, and the 10% additional tax may apply. There are three ways out.

RouteWhat it takesCostLimit
Automatic waiverThe financial institution got the funds before day 60 and a mistake on its side kept them out of the IRA; deposit within 1 year of the start of the 60 daysNonePub. 590-A (2025) lists five conditions, all required
Self-certificationA signed letter to the plan or IRA trustee giving one of 12 reasons, and a deposit as soon as practicable; 30 days after the reason ends is a safe harborNo IRS feeNot an IRS waiver; the IRS can disagree on audit; no prior IRS denial for the distribution (Rev. Proc. 2020-46 section 3.02)
Private letter rulingRequest under Rev. Proc. 2003-16 and 2026-4$18,500 user feeThe IRS weighs errors by the institution, illness, use of the money and time passed

Source: IRS Publication 590-A (2025), Ways to get a waiver of the 60-day rollover requirement; Rev. Proc. 2020-46, section 3.

The twelve reasons in Rev. Proc. 2020-46 section 3.02(2) are: an error by the financial institution; a check misplaced and never cashed; money deposited in an account mistakenly thought to be a retirement plan; severe damage to the principal residence; a death in the family; serious illness of the taxpayer or a family member; incarceration; restrictions by a foreign country; a postal error; a levy under section 6331 whose proceeds were returned; delay by the distributing party in providing information the receiving plan required; and a distribution to a state unclaimed property fund. Pub. 590-A adds a point that matters for the next section: “The IRS can waive only the 60-day rollover requirement and not the other requirements for a valid rollover contribution.”

Two special clocks exist. A qualified plan loan offset, meaning a loan in good standing offset because the plan ends or you leave the job, can be rolled over by the due date of the tax return, with extensions, for the year of the offset; any other offset gets 60 days. And a frozen deposit does not count against the 60 days (26 U.S.C. 402(c)(7)).

What the 20% costs if you take the check

Pub. 575 (2025) gives the arithmetic in a $10,000 example: the payer withholds $2,000, you receive $8,000, and “you will have to get $2,000 from some other source to add to the $8,000” to roll over the entire $10,000. If you roll over only $8,000 the $2,000 is included in income, and the 10% additional tax may apply to it if you are under 59½. Scaled to larger balances (our arithmetic, all pretax):

Gross distributionWithheld (20%)Cash you receiveOther money to roll over 100%Included in income if you roll over only the cash10% additional tax on that amount, under 59½
$250,000$50,000$200,000$50,000$50,000$5,000
$500,000$100,000$400,000$100,000$100,000$10,000
$1,000,000$200,000$800,000$200,000$200,000$20,000

Source: arithmetic on 26 U.S.C. 3405(c)(1) and IRS Publication 575 (2025) (payment-to-you option and Table 1). Income tax rates are not applied. Hypothetical balances.

The exceptions to the withholding are narrow. Pub. 590-A says the payer does not have to withhold if the year's eligible rollover distributions from the plan total less than $200, or if the distribution is only employer securities plus $200 or less of cash for fractional shares. Pub. 575 adds that NUA on employer stock is not withheld; see our page on net unrealized appreciation before moving company stock into an IRA.

Where the once-a-year rule applies and where it does not

The limit is in 26 U.S.C. 408(d)(3)(B): the rollover rule “does not apply to any amount” received from an IRA “if at any time during the 1-year period ending on the day of such receipt such individual received any other amount” from an IRA that was not taxed because of the rollover rule. Pub. 590-A (2025) puts it as “You can make only one rollover from an IRA to another (or the same) IRA in any 1-year period regardless of the number of IRAs you own”, and Announcement 2014-15 explains that the IRS adopted the Tax Court's aggregate reading in Bobrow v. Commissioner for IRA distributions from January 1, 2015.

MoveCounts toward the once-a-year limit?Source
401(k) or other employer plan to an IRA (direct or 60-day)No. The limit is on IRA-to-IRA rolloversPub. 590-A (2025), No waiting period between rollovers
Several distributions from the same employer plan in one yearNo. You can roll over more than onePub. 590-A (2025)
IRA to IRA by 60-day rolloverYes, once in any 1-year period across all your IRAs26 U.S.C. 408(d)(3)(B); Pub. 590-A (2025); Announcement 2014-15
IRA to IRA by trustee-to-trustee transferNo. It is a transfer, not a rolloverPub. 590-A (2025); Announcement 2014-15
Traditional IRA to Roth IRA conversionNoPub. 590-A (2025)
IRA to an employer planNo on the statute's wording: the limit refers to amounts paid into an IRA, and Table 1-4 puts the 12-month footnote only on IRA-to-IRA cells26 U.S.C. 408(d)(3)(B); Pub. 590-A (2025) Table 1-4 (our reading)

Source: as cited. The last row is our reading of the statute and the chart.

The date logic: “The 1-year period begins on the date you receive the IRA distribution, not on the date you roll it over into an IRA.” In practice that means the rule is usually triggered after the plan money has already landed. A reader who rolls a 401(k) into IRA-1 and then takes a check from IRA-1 to move it to a self-directed IRA custodian has made the one IRA-to-IRA rollover for the next year; a second such check from any of their IRAs inside the 1-year period would be taxable and, Pub. 590-A notes, cannot be waived. The fix is the one the Announcement names: a transfer straight from one IRA trustee to the other “is not a rollover”.

What cannot be rolled over

Only an “eligible rollover distribution” can move tax-free to an IRA. 26 U.S.C. 402(c)(4) removes three things from it, and Pub. 590-A (2025) lists more.

Not rollableSourceWhat a reader does
Required minimum distribution under 401(a)(9)26 U.S.C. 402(c)(4)(B); Pub. 590-B: “Amounts that must be distributed (required minimum distributions) during a particular year aren't eligible for rollover treatment”In an RMD year, take the RMD out of the plan first; only the rest can roll. See our page on [RMDs with illiquid IRA assets](/articles/required-minimum-distribution-illiquid-ira-assets-2026)
Hardship distribution26 U.S.C. 402(c)(4)(C)A hardship payout stays taxable income
Substantially equal payments over life, joint lives or 10 years or more26 U.S.C. 402(c)(4)(A)Ask whether the plan has you on a payment series before choosing
Corrective distributions of excess contributions or deferralsPub. 590-A (2025)Ask the plan; these are reported separately
A loan treated as a distribution, unless the benefit is reduced (offset) to repay itPub. 590-A (2025)A defaulted loan cannot be rolled; a qualified offset can, by the tax return due date
Dividends on employer securities and the cost of life insurance coveragePub. 590-A (2025)Both are outside the rollover
A life insurance contract itselfPub. 590-A (2025): “You can't roll over a life insurance contract from a qualified plan into a traditional IRA.”Surrender it and roll the cash only if the plan treats it as distributable

Source: 26 U.S.C. 402(c)(4); IRS Publication 590-A (2025), Rollover From Employer's Plan Into an IRA; IRS Publication 590-B (2025).

After-tax money and the pro-rata split

If the 401(k) holds both pre-tax and after-tax dollars, Notice 2014-54 sets how they divide when one distribution goes to several places. Disbursements made at the same time are treated as a single distribution with a pro rata share of each. For direct rollovers, the notice says the pretax amount goes first to the direct rollover. Its Example 1 uses a $250,000 balance of $200,000 pretax and $50,000 after-tax, a $100,000 distribution, and gets an $80,000 pretax share. A $70,000 direct rollover to a new plan is all pretax; the $30,000 paid to the employee is $10,000 pretax and $20,000 after-tax; a later 60-day rollover of $12,000 to an IRA is $10,000 pretax and $2,000 after-tax. Pub. 575 (2025) adds that after-tax contributions you roll into a traditional IRA “become part of your basis (cost) in your IRAs” and are tracked on Form 8606. See our page on the pro-rata rule with illiquid IRA assets for what that basis does later.

The age 55 exception does not follow the money

The 10% additional tax is the cost most readers between 55 and 59½ do not see until after signing. 26 U.S.C. 72(t)(2)(A)(v) exempts a distribution “made to an employee after separation from service after attainment of age 55”. Section 72(t)(3)(A) then says: “Subparagraphs (A)(v) and (C) of paragraph (2) shall not apply to distributions from an individual retirement plan.” Subparagraph (C) is the QDRO exception. Pub. 575 (2025) requires the separation to occur “in or after the year in which you reach age 55”, and its example has a man who left at 49 and took money in the year he reached 55, which does not qualify.

Exception to the 10% additional taxQualified plan (Pub. 575)Traditional IRA (Pub. 590-B)
Separation from service in or after the year of age 55YesNo (26 U.S.C. 72(t)(3)(A))
Qualified domestic relations order, payment to an alternate payeeYesNo (26 U.S.C. 72(t)(3)(A))
First home, up to $10,000Not listedYes
Qualified higher education expensesNot listedYes
Health insurance premiums during unemploymentNot listedYes
Disability, death, terminal illness, substantially equal payments, medical expenses over 7.5% of AGI, IRS levyYesYes

Source: IRS Publication 575 (2025), Tax on Early Distributions; IRS Publication 590-B (2025), Early Distributions; 26 U.S.C. 72(t)(2) and (3)(A). Lists abbreviated; the CSV has all 15 rows for both account types.

At age 57, a $50,000 withdrawal costs $5,000 of 10% additional tax from an IRA and $0 from the plan if the exception applies, in both cases before income tax (our arithmetic). The Form 1099-R instructions confirm the plan side: code 2 is used for “a distribution from a qualified retirement plan after separation from service in or after the year the participant has reached age 55”. The practical sequence follows from that: money you may need before 59½ is taken from the plan first, and the rest is rolled.

If the destination is a self-directed IRA

Nothing in Pub. 590-A, Pub. 575 or the Code treats a rollover into a self-directed IRA differently from a rollover into any other IRA; the custodian is the trustee who accepts the money. We found no IRS text that changes the rollover step for a self-directed custodian, which is our reading. What differs is what happens next, and where the rollover touches illiquid assets.

  • Cash or property in. A plan usually pays cash. If the plan pays property, Pub. 575 says “You can't keep the distributed property and roll over cash or other property”: roll the actual asset or sell it and roll the proceeds, and 26 U.S.C. 402(c)(1)(C) requires that the amount transferred “consists of the property distributed”. Selling and rolling the proceeds causes no gain or loss (402(c)(6)).
  • Direct rollover to a self-directed custodian. The check rule of Q&A-4 applies: payable to the custodian “as trustee of” your IRA, or it is a payment to you with 20% withheld.
  • After the money lands. Pub. 590-B says an IRA with $1,000 or more of unrelated trade or business gross income “must file a Form 990-T”; investing in collectibles is treated as a distribution; a prohibited transaction can end the IRA. Our pages on self-directed IRA real estate rules, Form 990-T for IRAs and SDIRA custodians cover those rules.
  • Required withdrawals later. An IRA holding a non-traded fund still owes its RMD; see RMDs with illiquid IRA assets.
  • Staying in the plan. For readers weighing a plan that offers private assets, see the DOL 401(k) alternative investments rule.

Before a sales channel moves it

FINRA Regulatory Notice 13-45 (December 30, 2013) said rollovers from employer plans were the largest source of contributions to IRAs, and that the party recommending one is often paid if you move and not if you stay: “a recommendation that an investor leave his plan assets with his old employer or roll the assets to a plan sponsored by a new employer likely results in little or no compensation for a firm or a registered representative.” It lists seven factors a rollover recommendation should weigh, and says it would be “false and misleading to imply that a retiree's only choice, or only sound choice, is to roll over her plan assets to an IRA sponsored by the broker-dealer”. The Notice is 2013 guidance under the suitability rule it cites; 17 CFR 240.15l-1 now requires a broker-dealer making “a recommendation of any securities transaction or investment strategy involving securities (including account recommendations) to a retail customer” to act in the retail customer's best interest. We read the Notice for its factor list, not for the current legal standard.

FINRA factor (Notice 13-45)Question to put in writing before the transfer
Investment optionsWhat can the IRA hold that the plan cannot, and do you want it?
Fees and expensesPlan fees, fund expense ratios and the IRA's account, custodian and advisory fees, side by side
ServicesDoes the plan offer advice, tools or a help line the IRA would not?
Penalty-free withdrawalsDo you need money between 55 and 59½? The plan can pay without the 10% tax after separation at 55; an IRA generally cannot
Creditor protectionHow does your state protect IRA assets compared with the plan? Ask a lawyer; federal and state rules differ
Required minimum distributionsStill working at the plan's company? The Notice says you generally need not take RMDs from your current employer's plan while you work there
Employer stockDoes the plan hold appreciated company stock? Rolling it to an IRA gives up NUA treatment

Source: FINRA Regulatory Notice 13-45 (December 30, 2013), section 2; 17 CFR 240.15l-1(a)(1). The questions are our wording of the Notice's factors.

What a reader can do with this

  • Choose direct. Unless you need the cash, ask the plan for a direct rollover and for the check, if any, to be payable to the IRA trustee “as trustee of” your IRA. Ask whether it can pay more than one destination.
  • If you took the check, count 60 days from receipt, put the withheld 20% back from other money if you want the whole amount rolled over, and write the deposit date down.
  • Move IRA to IRA by transfer, not by check. After the plan money reaches an IRA, a trustee-to-trustee transfer is not limited by the once-a-year rule.
  • In an RMD year, get the RMD out first. It cannot be rolled over.
  • Between 55 and 59½, ask for the bridge money before the rollover. The age 55 exception does not survive in an IRA.
  • Ask whether any of it is after-tax, and whether the destination IRA will report basis on Form 8606.
  • Keep the records: the plan's 402(f) notice, the Form 1099-R (code G for a direct rollover), the IRA's Form 5498 and, if late, the self-certification letter.
  • Do not decide on this page. Which route fits depends on your plan's terms, your age, your other IRAs and your state; that is for a CPA or adviser with your documents.

For how to choose among advisers by fee structure, see what a fee-only financial advisor is.

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Sources, read and saved on October 22, 2026: 26 U.S.C. 72, 401, 402, 408 and 3405 (Cornell Legal Information Institute); 26 CFR 1.401(a)(31)-1 (Cornell LII); 17 CFR 240.15l-1 (Cornell LII); IRS Publications 590-A (2025), 590-B (2025) and 575 (2025); Instructions for Forms 1099-R and 5498 (2026); IRS Rev. Proc. 2020-46; IRS Notice 2014-54; IRS Announcement 2014-15; FINRA Regulatory Notice 13-45 (December 30, 2013). Worked examples are our arithmetic on hypothetical figures. This is analysis of public documents, not investment, legal or tax advice.

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