I have the same situation and last year filed on form 4852 as 1099R substitute (as Germany does not provide any 1099R) and used dummy Fed ID 99-0999999 - and explain in words what and why are you reporting. This let me file it last year. I plan doing the same this year (as well as for German Social Security I am collecting).
Have not heard from the TT Tax experts that this is the WRONG way of doing???
