1099R distribution code(s) for In-plan Pre-tax to Roth conversion

[KaJay]

Background: 403(b)(9) non-electing church plan, participant wants to convert his pre-tax money ($10K) to a designated Roth account within the same plan.

The plan is getting hung up on "conversion" vs "rollover" when there is no distributable event. I only seem to see the term "in-plan Roth rollover (IRR)" these days, and information I see about "Roth conversions" is generally associated with an IRA to Roth IRA. The 1099R instructions state: An IRR is a rollover within a retirement plan to a designated Roth account in the same plan. Yet, there is no plan consensus. 😕

Three scenarios:

A - Participant is under age 59.5, still employed and contributing.

B - Participant is under age 59.5 and severed from employment.

C - Participant is over age 59.5.

It is agreed that box 2a would be 10K, but there is disagreement as to how this transaction is to be reported in box 7 on 1099R and I am hoping someone could offer clarity (TIA). 

What is the appropriate code(s) for box 7 and is it the same in all three "in-plan" scenarios? 

 

[Madison71]

I would think A and B would be Code 1 and C would be Code 7

[Artie M]

A--Code 2 (Early distribution, exception applies), G (Direct Rollover)

B--Code 2 (Early distribution, exception applies), G (Direct Rollover)

C--Code 7 (Normal distribution), G (Direct Rollover)

Box 1--$10,000
Box 2a--$10,000
Box 4--$0

[Madison71]

....Artie beat me to editing my response after thinking about it to add the G. I'm blaming it on being late Friday afternoon and March Madness....although I would have still been wrong, because I wasn't going to change the Code 1 from A and B. Sorry