As plan administrator, you are responsible for all distribution reporting. There is no third-party custodian to handle this on your behalf. Four distinct reporting obligations apply whenever a distribution is taken from the plan.
The first step is internal. Update your plan ledger to reflect the distribution, noting the participant account from which funds were drawn, the amount, the date, and the distribution type. If you have multiple participant accounts (pre-tax, Roth, or separate spousal accounts), each must be tracked separately. The Distribution Request form completed at the time of the distribution should be filed with your plan records.
Form 1099-R reports the distribution to the IRS and to the participant. As plan administrator, you produce this form yourself. It must be filed with the IRS by February 28 of the year following the distribution. A copy must also be provided to the participant (which in most cases is you).
The form requires you to identify the gross distribution amount, the taxable amount, and the applicable distribution code. The distribution code tells the IRS whether the distribution is qualified, subject to early withdrawal penalty, a direct rollover, or another category. Using the correct code matters. When in doubt, consult your CPA.
Form 945 reports all federal income tax withheld from non-payroll distributions during the year. It is due by January 31 of the year following the distribution. This form covers the withholding you deposited through EFTPS at the time of the distribution. If no distributions occurred during the year, the form does not need to be filed.
The distribution is reported on your personal federal tax return for the year it was received. The amounts from your 1099-R flow to your return and determine the taxable income and any penalty owed. Roth distributions that meet the qualified distribution requirements are excluded from income.
If your plan assets exceed $250,000 at year end, you are required to file Form 5500-EZ. Total distributions taken during the year are one of the line items reported on that form. The filing deadline is July 31 of the following year.
This information is provided for educational purposes only and should not be interpreted as tax, legal, or investment advice. Readers are encouraged to consult a qualified professional who can offer guidance based on their personal situation.