Yeah, that's my interpretation. Wish I could confirm, but I'm not an expert. But the final 8915-F does have a nice flow chart and an explicit place for reporting this. See the final here: https://www.irs.gov/pub/irs-pdf/f8915f.pdf. Specifically, it's going to be entered on line 23. If you look at the worksheet in the instructions, that's what ends up being put there.
As for the 1099-R, in my case when I took money out of my pension, the administrator didn't even ask or know I was doing a 3-year taxation. I think only me, TurboTax and the IRS knows that. So I wouldn't expect another 1099-R. But, I also wouldn't expect one if there truly is no "distribution" event in 2021 as I suspect is the case.
The IRS couldn't possibly have made this more confusing. Our tax code and the documentation of it is so bad.
Tony
