Under what circumstances are practitioners having participants complete Form W-4R for lump sum distributions of balances under $200. Prior to 2023, based on the wording in the Special Tax Notice, the plans we administer did not withhold on lump sum distributions under $200. If the participant wanted federal income tax withheld, they would need to elect the withholding percentage on the distribution form. Is 20% withholding (or more) now the only option? Does Form W-4R not have to be provided because the plan is not required to withhold- even though it is an eligible rollover distribution, just not one that a direct rollover option is provided.