This is not so much an executive compensation matter, but it is my understanding that pension professionals have long thought that so long as an individual did not take more than one rollover from one IRA/qualified plan to another with the SAME account, one could take several IRAs at one time, for example, and roll them to other IRAs. And why not, IRS publication 590 said exactly that. Nonetheless, the IRS pursued a couple who had done just that only to have the Tax Court agree with the IRS that no matter how many IRAs, you can only do one rollover within a twelve month period. To be sure, most people don’t do IRA rollovers because of the tax withholding involved. Most just do direct transfers thereby avoiding the withholding rules and in general making life simpler. But how absurd that the IRS would pursue a taxpayer for following clear IRS guidance?
Unbelievable. Here is more. http://www.marketwatch.com/story/ira-rollover-ruling-stuns-advisers-and-savers-2014-04-04?pagenumber=2