In 2016 the IRS released Revenue Procedure 2016-47,[1] providing the ability for an individual to self-certify specific reasons why they had not been able to roll over an IRA or qualified plan distribution within 60-days, qualifying for late rollover relief so long as the holder was able to document the self-certified reason if later required to by the IRS.

The IRS has now reissued the relief[2] to add a new self-certification reason:

In response to requests from stakeholders, this revenue procedure modifies that list by adding a new reason: a distribution was made to a state unclaimed property fund.[3]

Aside from adding the new exception (“…the distribution was made to a state unclaimed property fund.”),[4] no other changes were made to the prior ruling. However, Revenue Procedure 2020-46 includes the revised example certification, as well as the text of the other provisions in the original ruling.

Thus, the current list of reasons for a late rollover that the taxpayer may self-certify are:

An error was committed by the financial institution receiving the contribution or making the distribution to which the contribution relates;
The distribution, having been made in the form of a check, was misplaced and never cashed;
The distribution was deposited into and remained in an account that the taxpayer mistakenly thought was an eligible retirement plan;
The taxpayer's principal residence was severely damaged;
A member of the taxpayer's family died;
The taxpayer or a member of the taxpayer's family was seriously ill;
The taxpayer was incarcerated;
Restrictions were imposed by a foreign country;
A postal error occurred;
The distribution was made on account of a levy under § 6331 and the proceeds of the levy have been returned to the taxpayer;
The party making the distribution to which the rollover relates delayed providing information that the receiving plan or IRA required to complete the rollover despite the taxpayer's reasonable efforts to obtain the information; or
The distribution was made to a state unclaimed property fund.[5]

[1] The ruling was described in detail in the article “IRS Provides for Automatic Qualified Plan/IRA Late Rollover Relief” published on the Current Federal Tax Developments site on August 24, 2016. https://www.currentfederaltaxdevelopments.com/blog/2016/8/24/irs-provides-for-automatic-qualified-planira-late-rollover-relief (retrieved October 17, 2020)

[2] Revenue Procedure 2020-46, October 16, 2020, https://www.irs.gov/pub/irs-drop/rp-20-46.pdf (retrieved October 17, 2020)

[3] Revenue Procedure 2020-46, p. 1

[4] Revenue Procedure 2020-46, p. 3

[5] Revenue Procedure 2020-46, p. 3