Beneficiary IRA indirect rollover 1099-R

My mother (over 70 1/2) was the beneficiary of a Traditional IRA owned by my father (over 70 1/2) who passed in 2015. The normal distribution had not been taken at the time of my father’s passing. Ownership of the IRA was transferred to my mother and the full normal distribution for 2015 was received by my mother in June 2015 (taxes withheld). In August 2015, my mother decided to change financial institutions and a check was written to my mother (no taxes withheld) from the original bank (Bank “A”). The check was deposited the same day and a new IRA was opened at Bank “B”. In January 2016 she received form 1009-R issued from Bank A. Box 1 (Gross Distribution) and Box 2a (Taxable amount) showed the 2015 normal distribution amount + the rollover amount. Both boxes 2b were checked for “Taxable amount not determined” and “Total distribution”. Boxes 4 and 12 showed the correct amounts of Federal and State taxes withheld from the normal distribution amount. Distribution code in Box 7 indicates “4” for death (???). Since the 1099-R shows a Full Distribution, it appears that my mother must pay Federal and State taxes on the amount over the normal distribution amount even though the IRA was rolled over within 60 days. So, it seems that the rollover was not reported to the IRS. Whose responsibility was it to report the rollover to the IRS? Bank A? Bank B? Is the 1099-R accurate? Why was box 7 a code 4?



  • I assume that what you describe as a normal distribution was your father’s RMD. The 1099R she received is correct and it sounds like she rolled over the rest of the IRA balance properly to a new IRA in her name as owner, but did not roll the RMD over since the RMD is not eligible to be rolled over.  Due to the rollover, there will be no taxes due on that amount, just on the RMD. Bank B will report the receipt of a rollover contribution on Form 5498 that she will receive in May and the IRS gets their copy so will know that a rollover was completed.
  • To report the 1099R on her 2015 return (final joint return she can file), line 15a will show the gross distribution, and line 15b will only show the RMD amount. “Rollover” is entered on the line next to 15b to tell the IRS that amount not reported on line 15b (taxable amount) was rolled over.
  • Box 7 was coded 4 because the owner of the IRA (father) is deceased.
  • Note that it is possible that some portion of the RMD was not taxable if your father ever made non deductible contributions to his IRA. SInce he was taking RMDs, check the 2014 return to see if Form 8606 was attached. That form calculates the non taxable amount of his RMD if applicable. If you do not see an 8606 and if the 2014 line 15b was the same as 15a, then there was no non deductible amounts inherited by your mother that would transfer to her IRA.
  • Tell your mother to be very careful doing rollovers since she is only allowed one such rollover in a 12 month period. If she wants to move funds to a new custodian, it should be done by direct transfer since there is no limit on direct transfers. She also would not need to report direct transfers. Again, she cannot take a distribution and roll it over before August, 2016 since her last distribution rolled over was in August, 2015. If she were to take a distribution before then, she could not roll it over at all and what you feared had happened in 2015 would then actually happen in 2016.
  • Also check that her new IRA is titled with your mother as owner, not as beneficiary. For 2016 if she has reached 70.5, she would have to take her own RMD by year end.

Thank you for the thoughtful, thorough, and informed response. Just a clarification regarding the following statement from the 5th bullet item:“Again, she cannot take a distribution and roll it over before August, 2016 since her last distribution rolled over was in August, 2015.”My mother requested her 2016 RMD to be paid quarterly with the first payment due around April 1. Was she supposed to wait until after August 2016? Or was your statement referring to a distribution in conjunction with another rollover?

The limitation only applies to distributions that are rolled over. RMDs cannot be rolled over, so the 4/1 payment is not a problem.

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