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Withholding for Pension Administrators Frequently Asked Questions (FAQ)


Changes to Michigan Withholding Tax and Who Will be Affected

  1. Which pension benefits are taxed?

    Under Michigan law, qualifying pension and retirement benefits include most payments that are reported on a 1099-R for federal purposes. This includes defined benefit pensions, IRA distributions, and most payments from defined contribution plans.

    Payments received before the recipient could retire under the provisions of the plan or benefits from 401(k), 457, or 403(b) plans attributable to employee contributions alone are taxable under Michigan law.

  2. Should taxes be withheld from military pension or railroad retirement benefits?

    No, they are exempt from tax.

  3. What are the changes for recipients born before 1946?

    There are no changes for those born before 1946.

    For recipients born before 1946, all benefits from public sources are exempt and benefits from private sources may be deducted up to $53,519 for a single or married filer filing separately or $107,517 for married filing a joint return for the 2020 tax year. Any private pension payment in excess of the limits above is taxable.

  4. What are the changes for recipients born during the period 1946 through 1952?

    For recipients born during the period January 1, 1946 through December 31, 1952, a single filer may subtract $20,000 against all income and joint filers may subtract $40,000 against all income as the Michigan Standard Deduction on Schedule 1, line 23. for joint filers of all private and public pension and retirement benefits may be deducted from Michigan taxable income.

    Pensions from employment with governmental agencies not covered by the SSA. $35,000 for single filer, $55,000 for joint filers, or $70,000 for joint filers if both spouses worked for an “uncovered” agency.


  5. What are the changes for recipients born after 1952?

    For most taxpayers born after 1952, there is no pension deduction in 2020. However, for some taxpayers in Tier 3, at age 62 there is the limited deduction if a taxpayer receives a pension from employment with a governmental agency that was not covered by the federal SSA. The “uncovered” taxpayer, who is at least 62, may deduct up to $15,000 or up to $30,000 if both spouses were “uncovered.” If the “uncovered taxpayer” had retired as of January 1, 2013, then beginning in 2018 the deduction increases to $35,000 of pension income on a single return and up to $55,000 of pension income on a joint return ($70,000 on a joint return if both spouses were "uncovered").

    Most taxpayers in Tier 3 are eligible for the $20,000 single/$40,000 joint standard deduction upon reaching age 67. For “uncovered taxpayers” who had retired as of January 1, 2013, upon reaching age 67 the taxpayer may claim a standard deduction equal to $35,000 for single returns, $55,000 for joint returns, or $70,000 for joint returns if both spouses are “uncovered.”

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Registration Process

  1. When should a pension administrator register?

    Pension administrators may register at any time, but must register as soon as you know you have a Michigan resident(s) to which you pay pension and/or annuity payments.

  2. How does a pension administrators register for Michigan Withholding Tax?

    To register for Michigan Withholding Tax please visit Michigan eRegistration at Michigan Treasury Online (MTO) to e-register.

  3. If a company is currently registered with Treasury for a tax other than Michigan Withholding, does it need to register as a pension administrator?
    To register for Michigan Withholding Tax please visit Michigan eRegistration at Michigan Treasury Online (MTO) to e-register.

  4. Do companies who pay pension benefits/IRA withholding as well as payroll withholding need to make separate deposits?

    No, you are not required to make separate deposits. 

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Withholding Guide/MI W-4P

  1. Where can I find the withholding tables or the withholding formula?

    The withholding tables and/or withholding formula are available in the Withholding Guide. They can also be located on the website at

  2. Where can I get a Withholding Guide?

    The guide is available on the web at

  3. In the absence of an MI W-4P, can the pension administrators substitute it with the Federal W-4P?

    No.  Pension administrators may rely on or use substitute MI W-4P forms. For instance, a fillable form on a pension administrator's website for pension or IRA recipients to complete online is an acceptable alternative to paper forms.

    In general, the substitute form needs to convey the same basic information that is on the Department's MI W-4P form. The Department is not requiring a review and approval for substitute forms at this time.

  4.  What should be done if no MI W-4P is submitted?

    • Do not withhold on benefits paid to recipients born before 1946 unless the benefits exceed private pension limits ($53,759 single and $107,517 joint).
    • Withhold on all taxable pension distributions at 4.25% if the recipient was born in 1946 or after.
  5. Can the withholding table or withholding formula in Form 446 be used for everyone?

    No. If you were born in 1951 or before, you must use the withholding tables/formulas found in Form 4927-T and 4927-SSA.

  6. What is the difference between the single and joint withholding tables?

    The tables are based on the allowable pension and retirement deductions based on your birth year and filing status (single or joint).

  7. What is the 4.25% formula for those born between 1946 and 1952?

    Withholding = [Pension or Retirement Payment subject to federal income tax – Monthly pension deduction – (Allowance per Exemption x Number of Exemptions)] x 4.25%

    Monthly Deduction Amounts
    Single pension deduction…………
    Married pension deduction…………
    Personal exemption allowance…………


    Pension Payment $2,100 (-) Single Pension Deduction $1,666.67 = $433.33

    $433.33 (-) ($366.67 x 1 Exemption) = $66.67

    $66.67 x 4.25% = $2.83 Monthly Withholding

  8. What is the withholding rate for those born after 1952?

    For recipients born after 1952, all pension and retirement benefits are subject to Michigan Income Tax Withholding. You may use the withholding tables in Form 446-T for the appropriate withholding based on the number of personal exemptions claimed on the MI W-4P. This guide can be found online at

  9. Can a pension recipient change their number of personal exemptions at any time?

    Yes, by submitting an updated MI W-4P to their Pension Administrator.

  10. We have recipients whose marital status is either widow(er) or divorced. When they complete the MI W-4P, which box should be checked?

    The single box should be checked.

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Withholding Information for Pensions, Annuities and other Retirement Payments

  1. Our organization is a 501(c)(3) Type I supporting organization. We do not file a Form 990.  We are a religious organization. What responsibility do we have to withhold on a Charitable Gift Annuity (CGA) for a MI beneficiary?

    Michigan follows federal guidelines therefore if you are required to withhold Federal Income Tax, you would be required to withhold Michigan Income Tax.

  2. Do the mandatory withholding requirements apply to trusts receiving IRA distributions as the beneficiary of an IRA?

    An IRA custodian or administrator is subject to Michigan’s pension withholding tax on any distributions that will be subject to Michigan income tax at the end of the year in the hands of the beneficiary. Distributions paid to a trust as an IRA beneficiary will be taxable at the end of the year and are subject to pension withholding.

  3. We are financial planners and are working with a custodian to withdraw money from a Roth IRA for one of our clients. Is a distribution from a Roth IRA taxable and subject to the 4.25% withholding?

    Law (MCL 206.703) requires pension withholding on any IRA distributions that will be subject to Michigan tax at the end of the year on the beneficiary’s Michigan income tax return. In general, distributions from Roth IRAs are exempt from both Michigan and federal income taxes, and no pension withholding would be required.

    However, if part of the distribution is taxable, then Michigan pension withholding would be required on the taxable portion of the distribution. A portion of the distribution from a Roth IRA may be taxable when a recipient receives a nonqualified distribution. Nonqualified distributions from Roth IRAs are determined by reference the Internal Revenue Code.

  4. A pension administrator withholds on a retiree’s distribution in January and pays the withheld money to Treasury in February. The pension administrator later discovers that the distribution was not subject to income tax. How can the retiree recover the withheld tax?

    In most cases, the pension administrator could directly refund the withheld amount to the retiree. Pension administrators can use the same procedures that are available to employers under the Michigan Administrative Code R 206.22(1). The rule provides that “[i]f an employer over withholds income tax from an employee’s wages, or if he withholds Michigan tax where he should not have withheld Michigan tax, he may repay the amount withheld in error to the employee at any time within the same calendar year. … The employer may adjust his records internally and deduct the amount refunded from the tax owing on his next tax return ….”

    Example.   A pension administrator deducted $150 from George’s January pension distribution and paid the withholding to Treasury on its January return. However, George was born in 1939 and owes no tax on his pension. The pension administrator could pay George the $150 that was mistakenly withheld and then reduce its February withholding payment to Treasury by $150. The pension administrator would simply have $150 too much in its January monthly withholding return and $150 too little in its February monthly withholding return. At the end of the year when the pension administrator files its Sales Use and Withholding annual return (form 165) it would reconcile its total withholding for the year against its monthly returns and against the withholding reported on 1099Rs.

    If the pension administrator is unable to repay the retiree by way of internal adjustments to its monthly withholding returns, the retiree will not be able to seek a refund from Treasury until the retiree files an income tax return following the close of the tax year.

  5. Is there a minimum one time distribution amount from a taxable pension distribution that does not require Michigan tax withholding?

    One time distributions from employer retirement plans or IRAs are only subject to Michigan pension withholding if the distribution exceeds the exemption allowance for the number of personal exemptions claimed on line 5 of the MI W-4P.

    Note: This applies to any one time distribution not just those that fall under the minimum distribution rules.

    For a person claiming one exemption in 2020, the distribution would have to be in excess of $4,750. For a person claiming 0 exemptions, withholding payments of less than $1 are not required.

  6. Are Michigan withholding requirements on distributions from an Employee Stock Ownership Plan (ESOP) voluntary or mandatory?

    Michigan's pension withholding requirements are mandatory on retirement or annuity payments that will be taxable to the recipient and reported by the payor on a 1099-R form at the end of the year.

    If distributions from an ESOP retirement plan meet these conditions, Michigan's pension withholding is mandatory except to the extent provided for on a MI W-4P submitted by a recipient.

Withholding for Pension Administrators

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