If you ask someone who works with individual retirement accounts (IRAs) what “tax-year reporting” for IRAs entails, he/she would probably indicate that it means to accurately identify on Internal Revenue Service (IRS) Form 5498, IRA Contribution Information, the tax year for which an IRA regular contribution is made — which is true. However, is it possible that “tax-year reporting” could be applicable to other IRA transactions? The answer is yes, there are two distribution types that from a reporting standpoint may be use one of two different codes in Box 7 of IRS Form 1099-R, Distributions from Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc.
This article will examine how to report the removal of an IRA excess contribution, and a recharacterization distribution, both of which from a distribution reporting standpoint are dependent on the year the contribution was made vs. the year of distribution.
Excess Contribution Removal
To avoid a six percent penalty tax on an IRA excess contribution, an IRA owner must correct the excess contribution prior to his/her tax-filing due date, including extensions. This date is generally October 15 of the year following the year for which a contribution was made.
John Johnson, age 45, made a $7,000 traditional IRA contribution for 2020 on January 10, 2021. When John completed his 2020 tax return in April 2021, he learned that $1,000 of his contribution was not eligible. Because of this, John corrects the excess contribution by removing it with earnings attributable before October 15, 2021. As a result, John avoids a six percent penalty tax on the $1,000 excess contribution, however the earnings attributable to the excess are taxable.
How will the custodian/trustee of John’s traditional IRA report the distribution of John’s excess contribution on a 2021 IRS Form 1099-R?
The 1099-R reporting instructions provide two codes (i.e., 8 and P) for reporting the removal of an IRA excess contribution when completed before an IRA owner’s tax-filing due date. The appropriate distribution reporting code is determined by considering when the distribution takes place compared to when the contribution was made. If a contribution is made and removed in the same calendar year, report using Code 8. If a contribution is made during one calendar year but removed in the following calendar year (before the tax-filing deadline, including extensions), report using Code P.
In our example of John Johnson’s $1,000 IRA excess contribution, the contribution was made and removed in the same calendar year and therefore the appropriate distribution code in box 7 of the 2021 IRS Form 1099-R is “8”. Additionally, a “1” should accompany the “8” (i.e., Code 81) since John was younger than age 59½ at the time of distribution.
Recharacterization allows an IRA owner to treat an IRA regular contribution made to one IRA type as a contribution made to the other IRA type (i.e., traditional IRA to Roth IRA or Roth IRA to traditional IRA). If an IRA regular contribution is recharacterized to the other IRA type, an IRA owner is essentially changing the nature, or “character” of the initial contribution, not the tax-year for which the contribution was made. Furthermore, recharacterization of a contribution must be completed by the IRA owner’s tax-filing deadline, including extensions of the tax year for which the initial contribution was made. A tax year designation is not made for a recharacterized contribution. However, the year for which a contribution is made and subsequently recharacterized is important in determining the appropriate distribution code (i.e., R vs. N) used in Box 7 of IRS Form 1099-R.
Alan Peterson, age 53, made a $7,000 traditional IRA regular contribution for 2020 on January 10, 2021. When Alan completes his 2020 tax return in April 2021, he learns that his contribution is not deductible. Alan decides to recharacterize his 2020 traditional IRA regular contribution as a 2020 Roth IRA regular contribution. Alan has until October 15, 2021 to complete the recharacterization with his IRA custodian/trustee.
In this case, since Alan’s traditional IRA regular contribution was made for 2020 and is being recharacterized in 2021 the appropriate distribution code is “R” on the 2021 Form 1099-R.
If Alan’s contribution had been made in 2021 for 2021, and subsequently recharacterized in 2021, the appropriate distribution code would be “N” on the 2021 Form 1099-R.
Working with IRAs can seem especially tricky for anyone working on the front lines who may not be knowledgeable about reporting. When trying to determine which IRS reporting code applies to the removal of an excess contribution (i.e., P or 8) vs. recharacterization (i.e., N or R) it is important to remember that reporting the removal of an excess contribution takes into account the year during which a contribution was made whereas a recharacterization takes into account the year for which a contribution was made.For an opportunity to learn more about IRAs and other tax-advantaged accounts, including Health Savings Accounts and Coverdell Education Savings Accounts, consider the Wolters Kluwer IRA Library or on-demand video training offered on a variety of topics. Go here to learn more about training opportunities available to you or call us at 1-800-552-9408.