Finding this as maybe the closest match, to the scenario, I also find that this and this strongly suggest that NUA rules only apply to Employer stock purchases. In other words, if I work for Acme, then only Acme stock is in question here. So, in a portfolio with many options, only a portion of the whole may (in my understanding) have NUA rules applied; all other sources would follow those rules.

That said, everything I'm finding talks of distributions, not specifically Rollovers to another IRA. The rules and advise say that NUA rules are a tradeoff (taxes will be paid somewhere).

My question is simple, if I roll a portfolio, considering that means selling (realizing) the gain, is that the same as a "distribution" in terms of tax liability?

Thanks in advance.

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