Revenue Ruling 2025‑15 (available here) provides guidance on withholding and reporting obligations when a plan participant or beneficiary...
Revenue Ruling 2025‑15 (available here) provides guidance on withholding and reporting obligations when a plan participant or beneficiary fails to cash a distribution check and a replacement check is issued. As discussed below, the guidance is consistent with general constructive receipt principles.
When a qualified retirement plan pays a benefit to a plan participant or beneficiary, the payment is subject to withholding for income taxes (subject to limited exceptions that are not discussed here) and reporting on Form 1099‑R. Revenue Ruling 2025‑15 states that subsequent cancelation of the check due to the recipient's failure to cash the check would not trigger a right to refund of amounts withheld or change the reporting. A refund is not permitted unless there was an overpayment of taxes due to a calculation error, determined based on the facts at the time of the payment.
If the plan issues a second check to replace the uncashed first check, additional federal income tax withholding is not required unless the amount of the second check is greater than the amount of the first check (for example, due to crediting interest or additional earnings). If the second check is greater than the first check, additional withholding would be required on the additional...
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