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vyriy
New Member

I indicated that I need a substitute 1099-R form

What else I needed?
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5 Replies
DanaB27
Expert Alumni

I indicated that I need a substitute 1099-R form

Can you please provide more detail why you need a substitute From 1099-R?

 

 

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I indicated that I need a substitute 1099-R form

Rollover from an IRA annuity Trust to another IRA annuity Trust.  Transfering entity says it doesn't need to file a 1099-R. I believe they have a viable reporting position for tax information reporting purposes, but I want to report the rollover to establish section 403(b) employee contibutions that were previously taxed for state income tax purposes and provide notice on 2025 Massachusetts return of the amount of such significant contributions for future Massachusetts income tax purposes. TurboTax instructions advise that a substitute Form 1099-R can be prepared based on the best information available from taxpayer's records, which I have.  Should I simply add another 1099-R and attach a statement of explanation to the 2025 return? Or does TurboTax ask somewhere in the process whether I want to file a substitute Form 1099-R? 

dmertz
Level 15

I indicated that I need a substitute 1099-R form

A trustee-to-trustee transfer of an IRA is neither a distribution nor a rollover.  As such, it is not reportable.  A trustee-to-trustee transfer of an IRA does nothing to change your tax position with regard to your Massachusetts taxes.  Filing a substitute Form 1099-R would be a mistake.

 

To reiterate, this was not a rollover.  A trustee-to-trustee transfer of an IRA is no different than changing investments within an IRA.

I indicated that I need a substitute 1099-R form

Thanks dmertz for your input.  Let me explain further. Mass. taxpayer (public school teacher) established section 403 plan in 1996. For example purposes, employee contributions to the Plan from 1996 to her retirement in 2006 were $100,000.  For federal income tax purposes, all contributions to the Plan were pre-tax. For Massachusetts purposes, Contibutions prior to 1998 of $20,000 were after-tax. Thus her Mass. tax basis is $20,000. In 2012, she directed the trustee of her 403(b) plan to make a total distribution of $110,000 directly to the Trustee of IRA Annuity Trust A  ("IRA A"). This direct rollover distribution of $110,000 was reported by the 403(b) plan on 2012 Form 1099-R  (Distribution Code G); taxable amout zero.  IRA A filed 2012 Form 5498 reporting receipt of the $110,000 rollover contribution and provided taxpayer with a copy.  In early 2025, at the direction f taxpayer, the Trustee of IRA A made a total transfer of IRA assets to IRA Annuity Trust B ("IRA B"). No Form 1099-R was issued. Taxpayer has never received a distribution from either IRA A or IRA B. All required RMD requirements attibutable to IRA A though 2025 have been satisfied by distributions to taxpayer from a separate traditional IRA ("IRA C").  Taxpayer has never received a Form 1099-R from IRA A.  Again, for example, in 2025,  RMDs were IRA A ($10,000) and IRA C ($2,000) and were satisfied with a distribution of $12,000 from IRA C.  IRA A did provide taxpayer with a letter containing its computation of the 2025 IRA A  RMD.  Data input to TurboTax for IRA C shows that taxpayer satisfied her 2025 RMD with distibutions to her of $12,ooo from IRA C. But, without a 1099-R from IRA A, what input to TurboTax is needed  to prevent generation of Form 5329 Penalty?   

dmertz
Level 15

I indicated that I need a substitute 1099-R form

By aggregation, you effectively transferred the RMD requirement for IRA A from IRA A to IRA C.  Simply say that the RMD required for IRA C was $12,000 and that the $12,000 distribution from IRA C satisfied that RMD.  Nothing about How much RMD was required for each account is reported on your tax return, so there is no need to tell TurboTax anything about IRA A.

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