Withholding on Roth distrib under $200

[dcoderre]

1. For the exception from 20% mandatory withholding on distributions under $200, I believe we can consider the Roth & non-Roth portions separately. Do you agree? (See final regs under "modifications to final roth 401k regulations" on page 21108 of federal register.)

2. Does the $200 threshold for exception to withholding refer to only the taxable portion? For example, if the Roth distribution is $300, but only $100 is taxable because the basis is $200, is 20% withholding required on the taxable $100? I would think no withholding is required because the taxable portion is less than $200, but it's not clear to me when I look at treas reg 31.3405©–1, A-6 or the roth regs.

Thanks in advance for any information on this.