I transferred the entire balance from my son's ESA account to his 529 account. Both with Vanguard. On the 1099-Q for the ESA account, Vanguard coded box 6 (Distribution code) as 1 which applies for distributions including transfers. I never got hold of the funds as it was done by Vanguard. Vanguard also left box 4 empty as it did not consider this as a trustee-to-trustee transfer (as for ESA, Vanguard is a brokerage fir, not a trustee).
Do I need to inform the IRS that this was a transfer and not a withdrawal? If yes, how? Do I attach a note? or use form 8275 'Disclosure Statement'
