I actually got a conflicting opinion from another tax accountant (not from this forum). They said that basically the payer (Vanguard in this case) already determined that these payments to me are not subject to the penalty, and because of that, form 5329 is NOT required. They said that there is nothing wrong if I choose to add the form.
I would be curious to hear what your response is to this, as well as what other tax people in this forum think.
