Can HSA assets that have been rolled over within the past 12 months be transferred without tax implications?

  1. Request a rollover distribution from Custodian A
  2. Deposit funds distributed by Custodian A to Custodian B as a rollover
  3. Within 12 months, request a custodian-custodian transfer from Custodian B to Custodian C

As I understand it, you may make a rollover distribution of the assets only once per rolling 12 month period, but custodian-custodian transfers do not generate a taxable event and can be completed both instead of or in addition to a rollover with no further tax implications, regardless of when the transfer takes place.

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