Updated August 3, 2026. Quick answer: the difference between Q and T is not whether your distribution is taxable. It is whether your custodian could confirm your five-year clock. Code Q means it knew the five-year holding period was met; code T means it did not know — even though you are 59½, disabled, or the account owner has died.
What the IRS tells the payer
From the current instructions, code Q is “Qualified distribution from a Roth IRA”. The full instruction text is what the custodian is following when it picks this code.
The two instructions, side by side
Code Q is used “if you know that the participant meets the 5-year holding period” and the participant has reached 59½, died, or is disabled.
Code T is used “if you do not know if the 5-year holding period has been met” but one of those same three things is true.
Same underlying facts about you. Different state of the custodian’s records. Custodians routinely lack the history because the account was transferred between providers, and the clock does not transfer with the paperwork.
What to do with a code T
Work out your own five-year clock and report accordingly. If the period is met, the distribution is qualified regardless of what the custodian could verify — the code records their knowledge, not the law. If it is not met, only earnings are at issue, because Roth ordering rules take contributions out first — how Roth sits in the withdrawal order.
Keep your own record of when your first Roth contribution or conversion was made. It is the one piece of information nobody else reliably holds, and it is worth writing down somewhere permanent.
Box 7 is the payer’s claim, not the law
The code in Box 7 records what the custodian knew when it cut the cheque. It is not a ruling on what you owe, and the IRS instructions say so in as many words. On code 1 the instruction to payers is to use it “even if the distribution is made for medical expenses, health insurance premiums, qualified higher education expenses, a first-time home purchase…” and a list of other genuine statutory exceptions.
In other words the IRS expects the payer to report a distribution as unexcepted when the payer simply does not know, and expects you to claim the exception on your return. That is what Form 5329 is for, and it is the single most useful thing to understand about this form.
Every code in one place: the Box 7 table. If yours looks wrong: how to fix it.
Code meanings are read from the IRS Instructions for Forms 1099-R and 5498 (current edition, tax year 2026), Table 1 — Guide to Distribution Codes, at irs.gov on August 3, 2026. General information, not tax advice. Your own facts decide the outcome, and a preparer or the IRS is the right place to confirm anything consequential.