1099-R Form

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    I have a couple of questions about a Qualified Charitable Distribution I made from one of my retirement accounts in 2018. Following is my description of what happened. I’m using round numbers to simplify the discussion.

    The 2018 RMD for this account was $12,000. I made a QCD of $2,000 from this account, which leaves a remaining RMD of $10,000.

    On December 15 when the RMD was taken from the account, it was for the full $12,000. I called the plan administrator and was told (1) that my account was set on “automatic,” (2) that I needed to call the plan administrator prior to the processing of RMD to let it know that the amount to be removed on December 15 was $10,000 because I had already taken the $2,000 QCD, and (3) I could deposit $2,000 back into my account on a 60-day rollover, which I did.

    When I received the 1099-R from the company, it shows a Gross Distribution of $14,000 and a Taxable Amount of $14,000. It should have shown a Gross Distribution of $12,000 and a Taxable Distribution of $10,000. I called the company to ask for a corrected 1099-R and was told that could not be done and that I should work with my tax advisor to resolve the issue.

    I have the incorrect 1099-R, I assume I will be receiving a 5498 Form for the 60-day rollover, and I have paperwork from the plan administrator showing that it sent the charitable entity a check for $2,000 as well as a receipt from the charitable entity showing a $2,000 donation.

    So here are my questions: Will it be ethical for my accountant to take my explanation and my paperwork to prepare my 1040 Form showing that this account had a gross distribution of $12,000, a taxable amount of $10,000, and a QCD of $2,000 in spite of the fact my 1099-R shows $14,000 for both of these amounts? I do not expect my accountant to do anything that is not ethical, but I also don’t want to have to pay tax on the QCD amount, nor do I want to run afoul of IRS. Any input will be appreciated.


    Your post reminded me why I don’t have my IRA RMDs on auto though I would like to. Some companies seem to take other withdrawals into account and some don’t in pulling the RMDs.

    I think you’re probably fine. I know that companies,for some reason, don’t code the QCD as non-taxable so that is normal. Note that box 2b
    on your 1099R is ? marked “taxable amount not determined”…..if it’s not it should be since they don’t know what the correct amount is.

    So you let the IRS know the correct taxable amount and notate the tax return with “Rollover” and “QCD” so IRS knows why.
    https://www.irs.gov/pub/irs-pdf/i1040gi.pdf see instructions for line 4 on p. 29 exceptions 1 and 3. You should be careful in future years since you can only do 1 rollover every 12mos/365 days….it is not once a year…….so you might be a few days early in some future yr and violate the rule.

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