To be more clear, I should have said, "the distribution must be reported as a CRD on Form 8915-E to make it eligible for 3-year repayment and allowing it to be disregarded with respect to the one-rollover-per-12-months limitation." You don't have to report it as a CRD, but by not doing so you would be subject to the 60-day rollover deadline and it would be considered with respect to the one-rollover-per-12-months limitation. If you don't report it as a CRD, you aren't claiming it to be a CRD and it won't be treated as a CRD. If you qualify for this to be reported as a CRD, there is no downside to reporting it as a CRD (other than the delay in filing your tax return that will inevitably result from the amount of time it takes for this form to be implemented in TurboTax).
