The IRS issued further on the application of the Bobrow Decision today in the attached Announcement 2014-32. The guidance addresses/clarifies certain points:
The announcement also confirms that the one-rollover-per-year limitation does not apply to a rollover to or from a qualified plan (and such a rollover is disregarded in applying the one-rollover-per-year limitation to other rollovers), nor does it apply to trustee-to-trustee transfers.
IRA trustees are encouraged to offer IRA owners requesting a distribution for rollover the option of a trustee-to-trustee transfer from one IRA to another IRA.