"Rev. Rul. 2019-19 addresses the situation where the distribution check is in fact 'received' by the participant. It does not reach the more challenging set of related tax recognition, reporting and withholding issues that arise when plan disbursements are transmitted but not 'actually' received due to death or an incorrect address. In fact, employers and recordkeepers are rarely able to distinguish these situations from the facts in Rev. Rul. 2019-19 unless and until the check is returned as undeliverable[.]"  MORE >>