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A collectively bargained employee can be (if other conditions are met) one who is included in a collective-bargaining unit even if the employee is not a member of the labor union that serves as the unit’s representative. “The requirements of [IRC § 401(a)(4)] are treated as satisfied by a collectively-bargained plan that automatically satisfies section 410(b) under § 1.410(b)-2(b)(7).” 26 C.F.R. § 1.401(a)(4)-1(c)(5) https://www.ecfr.gov/cgi-bin/text-idx?SID=f3b5bc3ae83784c7e815b36bb79fbbab&mc=true&node=se26.6.1_1401_2a_3_24_3_61&rgn=div8 “A plan that benefits solely collectively bargained employees for a plan year satisfies this paragraph (b)(7) for the plan year. If a plan (within the meaning of § 1.410(b)-7(b)) benefits both collectively bargained employees and noncollectively bargained employees for a plan year, § 1.410(b)-7(c)(4) provides that the portion of the plan that benefits collectively bargained employees is treated as a separate plan from the portion of the plan that benefits noncollectively bargained employees. Thus, the mandatorily disaggregated portion of the plan that benefits the collectively bargained employees automatically satisfies this paragraph (b)(7) for the plan year and hence section 410(b). See § 1.410(b)-9 for the definitions of collectively bargained employee and noncollectively bargained employee.” 26 C.F.R. § 1.410(b)-2(b)(7) https://www.ecfr.gov/cgi-bin/text-idx?SID=474fc265e9f103c40593f277b1d96c6b&mc=true&node=se26.7.1_1410_2b_3_62&rgn=div8 “Collectively bargained employee means a collectively bargained employee within the meaning of § 1.410(b)-6(d)(2).” “Noncollectively bargained employee means an employee who is not a collectively bargained employee.” 26 C.F.R. § 1.410(b)-9 https://www.ecfr.gov/cgi-bin/text-idx?SID=474fc265e9f103c40593f277b1d96c6b&mc=true&node=se26.7.1_1410_2b_3_69&rgn=div8 “A collectively bargained employee is an employee who is included in a unit of employees covered by an agreement that the Secretary of Labor finds to be a collective bargaining agreement between employee representatives and one or more employers, [if] there is evidence that retirement benefits were the subject of good faith bargaining between employee representatives and the employer or employers. An employee is a collectively bargained employee regardless of whether the employee benefits under any plan of the employer. See section 7701(a)(46) and § 301.7701-17T of this chapter for additional requirements applicable to the collective bargaining agreement. An employee who performs hours of service during the plan year as both a collectively bargained employee and a noncollectively bargained employee is treated as a collectively bargained employee with respect to the hours of service performed as a collectively bargained employee[,] and a noncollectively bargained employee with respect to the hours of service performed as a noncollectively bargained employee. See § 1.410(b)-7(c) for disaggregation rules for plans benefiting collectively bargained and noncollectively bargained employees.” 26 C.F.R. § 1.410(b)-6(d)(2)(i) https://www.ecfr.gov/cgi-bin/text-idx?SID=474fc265e9f103c40593f277b1d96c6b&mc=true&node=se26.7.1_1410_2b_3_66&rgn=div8

@Pammie57,The plan administrator is the responsible withholding party. The IRS can recover the withholding , with interest, from the withholding party. The IRS will most likely not take any action if the tax liability is actually paid by the recipient of the distribution. If the participant does not pay the taxes owed, the IRS can recover from withholding party. The 1099-R should reflect what actually happened. If no withholding was done, you report no withholding.