Roth Qualified Distribution

[DTH]

The Form 1099-R instructions are not that clear on how to report designated Roth contributions from a retirement plan where the participant "meets" the qualified distribution rules (contributions in the plan for 5 years and the participant is age 59-1/2 or older, is disabled, or dies). Here the earnings are not taxable.

I assume that the designated Roth account (contributions + earnings) are tax reported as follows:

Box 1 = Gross amount (designated Roth contributions + earnings)

Box 2a = Taxable amount is 0.00

Box 5 = Designated Roth contributions + earnings

Box 7 = Category of distribution is a 7, 3, or 4 (T would only be used if payor doesn't know if participant meets the 5-year period)

Additionally, the 1099-R instructions indicate that a separate 1099-R be created for a designated Roth account distribution. If it meets the qualified distribution rules, can one 1099-R be used for a Roth and non-Roth distribution?

Thanks!

[Kimberly S]

My theory is that the instructions don't address it yet because Roth contributions have not yet been permitted for 5 years. Until 2011 the presumption is that no Roth distributions from 401(k) plans are qualified.