A participant who is above 59 1/2 years of age is seeking a distribution of excess deferrals (they paid $20,500 above the 402(g) limit) and attributable income ($2,452) to a ROTH 401k. The client made the contributions in 2022 to two separate employer plans, so neither plans were able to detect the over-contribution. Both are contributions were ROTH. The client is still employed by both employers and both allow in-service withdrawals. The participant caught the error and reported to both administrators and employers.
How would you code the 1099-R?
1. Would you process this as a "normal" distribution (Code 7). The IRS instructions for forms 1099-R from 2025 states that "Use Code 7: (a) for a normal distribution from a plan, including a traditional IRA, section 401(k), or section 403(b) plan, if the employee/taxpayer is at least age 59 1/2..."
or
2. would you use code 8—Excess contributions plus earnings/excess deferrals (and/or earnings) taxable in 2025. (this information is Instructions for Forms 1099-R and 5498 (2025). It states "Use Code 8 for a corrective IRA distribution under section 408(d)(4), unless Code P applies. Also, use this code for corrective distributions of excess deferrals, excess contributions, and excess aggregate contributions, unless Code P applies. See Corrective Distributions, earlier, and IRA Revocation or Account Closure, earlier, for more information."
or is there some other coding of the 1099-R?
Thanks!
