How do account changes made in the last 15 years impact eligibility for a tax-free 529-to-Roth IRA rollover?

The Oregon College Savings Plan does not currently have guidance from the IRS on whether adjustments, such as account owner transfers, beneficiary changes, or rollovers between 529 plans may impact the 15-year requirement for how long your 529 account must have been open to qualify for a tax-free rollover. A collaboration of state-administered college savings programs submitted a letter to the IRS in September 2023 seeking guidance on these issues, but rules have not yet been confirmed by the IRS. You should speak with a qualified tax professional prior to making a 529-to-Roth IRA rollover.