All of the following statements regarding qualified domestic relations orders (QDROs) are correct except

A)

an alternate payee who is the former spouse of the participant, and who receives a distribution by reason of a QDRO or other court order, may roll over the distribution in the same manner as if she were the participant (including to her own IRA).

B)

distributions made to an alternate payee under a QDRO outside of retirement accounts are subject to income tax.

C)

a QDRO may specify the time at which the alternate payee will receive the plan benefit (assuming the type of distribution is allowed by the plan document).

D)

distributions made to an alternate payee under a QDRO are subject to the 10% premature distribution penalty.