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At a practical level, the answer is "it depends on who is issuing the 1099-R." If I had a pooled plan and forms signed today, I would say the transaction happened today. If it's daily val'd and the recordkeeper does 1099s, I'm not arguing with them about it - whatever their system says wins; tough nuts for people who try to do things on 12/31.

Although a governmental plan’s fiduciaries who select service providers might be relieved from monetary liability under sovereign, governmental, or public-officer immunity, a governmental plan, its trust, and participants and beneficiaries might have remedies against those that receive excessive compensation. If a fiduciary of a governmental deferred compensation plan allows a direct or indirect payment (or use of the plan’s property or rights) that results in a service provider receiving more than reasonable compensation, the service provider must restore the excess (with income) to the plan if the service provider knew, or should have known, that what was allowed was more than reasonable compensation for the proper services provided. This principle — that even a nonfiduciary third person has duties concerning a trust — has been recognized in the common law since at least 1471. For this equitable principle, a person should know of a trustee’s or fiduciary’s breach when (i) he, she, or it knows facts that under the circumstances would lead an intelligent and diligent person to inquire into whether the trustee or fiduciary is breaching his, her, or its duty, and (ii) an inquiry, pursued with intelligence and diligence, would lead to knowledge (or reason to know) that the trustee or fiduciary is breaching his, her, or its duty. A service provider that receives a too-generous fee or other compensation might consider an old adage, “if it seems too good to be true, it probably is.” In applying this idea, reasonable compensation might be something more, perhaps considerably more, than fair-market compensation. And differences in the services, and in the persons that provide them, can make the comparisons untidy. Moreover, if the facts are that similarly situated governmental plans are paying similar compensation, it might be difficult to prove that the compensation is unreasonable. So far, the few settlements on litigations about governmental plans don’t give us enough information about how these claims would play if America’s plaintiffs’ lawyers pursued more of them.