Distribution Code for Roth Conversion with Tax Withholding

[Vlad401k]

What code should be used for a distribution from a 401k plan into a Roth IRA with the participant requesting 20% federal tax withholding?

I realize that if the participant does not request any withholdings, we use code G and indicate that the distribution amount is taxable. However, the issue that I have is that when a participant requests a 20% withholding, shouldn't that 20% amount be considered a distribution (early or otherwise, depending on age)? And if so, it does not seem like it would be possible to send only one 1099-R request with those instructions since code G cannot be used with code 1 (or 7, again depending on age). Should there be two 1099-R requests filed?

[Lou S.]

Good question but I think the withholding is a separate distribution subject to taxation and would need it's own 1099-R since it is not going to a ROTH-IRA.

[Appleby]

Agree with Lou S.