Non-direct RothK rollin

[Jed Macy]

How does a recipient qualified 401(k) plan report (and thereby comply with TR §1.402A-2 Q&A-3) receipt of a roll-in to its RothK accounts from a new participant's previous employer's RothK account where the rollin was not directly transferred but rather first paid to the participant and then paid in?

I didn't find any clues in the 2012 instructions to Forms 1099-R or 5498. Did I miss it? Is it some other form?

[masteff]

I'm not sure that you can do an indirect rollover to another qualified plan. http://www.irs.gov/pub/irs-tege/rollover_chart.pdf

[Jed Macy]

In the Explanation of Provisions - Overview to the 2007 Roth Final Regulations (TR §1.402A-2) is the following from page 22 with my underlining & bold:

As noted in the preamble, to the extent that a portion of a distribution is includible in income (determined without regard to the rollover), if any portion of that distribution is rolled over to a designated Roth account by the distributee rather than by direct rollover, the plan administrator of the recipient plan must notify the IRS of its acceptance of the rollover contribution. The final regulations clarify that this reporting is only required to the extent provided in Forms and Instructions. Such Instructions will specify the address to which the notification must be sent and will require the following information: (1) the employee's name and social security number; (2) the amount rolled over; (3) the year in which the rollover contribution was made; and (4) such other information as the Commissioner may prescribe in order to determine that the amount rolled over is a valid rollover contribution. Thus, until relevant Forms and Instructions are released, no reporting is required.

Thus, despite what the Rollover Chart indicates, it appears that it is (or at least was) expected that non-direct transfers are allowed; and that someday reporting of them would be required. Has that day arrived?