Roth Conversion and Form 5500

I generally see two schools of thought on this topic:

1. Process the conversion as a distribution and a rollover.

2. Process as a transfer and it is just a wash so no 5500 reporting.

Does anyone know of any formal or informal guidance on either of these?  I haven't been able to find anything.

I can't, off the top pf my head, refer you to any formal guidance on this. FWIW, I would not report this on the 5500. No distribution of plan assets has taken place. It is merely changing the taxation of the existing account. Now, if the option is chosen (if the plan permits) to allow a portion of the amount that may otherwise be "distributed" as an in-plan Roth rollover distribution, to be actually distributed solely for purposes of State or Federal income tax withholding purposes, then THAT amount I'd report on the 5500 as a distribution, since the plan assets have now actually been reduced.

37 minutes ago, Belgarath said:

I can't, off the top pf my head, refer you to any formal guidance on this. FWIW, I would not report this on the 5500. No distribution of plan assets has taken place. It is merely changing the taxation of the existing account. Now, if the option is chosen (if the plan permits) to allow a portion of the amount that may otherwise be "distributed" as an in-plan Roth rollover distribution, to be actually distributed solely for purposes of State or Federal income tax withholding purposes, then THAT amount I'd report on the 5500 as a distribution, since the plan assets have now actually been reduced.

Agree

Agree with Belgarath as well.