How to report hardship distributions on Form 1099-R after 12/31/99?

[Guest ralar]

What is the consensus on how to report hardship distributions on Form 1099-R after 12/31/99? Since hardship distributions coming from certain sources (i.e., elective deferrals and earnings) will not be eligible for rollovers, but hardship distributions coming from other sources (i.e., employer matching or profit sharing contributions, and) will still be eligible for rollovers, should two 1099-R's be used (one to report rollovers and one to report other hardship distributions) or should only one be used? If only one is used, how is the hardship distribution reported?

[Guest]

that would seem to agree with what was said at one of the ASPA sessions last week. (It was also a reason the speaker recommended to amend the plan to permit hardships from deferral only)

[bzorc]

I would think that you would still do only one 1099-R. The entire distribution is taxable, but only a part of it is now subject to the mandatory 20% withholding. Therefore, the distribution amount is still shown as the total distribution, the whole distribution is taxable, and the appropriate amount of withholding would be shown. The distribution code would remain "1", I believe.

Hope this helps!