The IRS has issued new Kind 8915-F to be used by particular person taxpayers to report retirement plan distributions as a result of certified disasters in addition to repayments of catastrophe distributions. Kind 8915-F is a “eternally kind,” designed for use for distributions for certified 2020, 2021, and later disasters, and for every year of reporting revenue from and compensation of these distributions. This can be a change to the method the IRS has taken since 2016, wherein a brand new kind was issued every year (Varieties 8915-A by way of 8915-E; see our Checkpoint article). For tax years starting after 2020, Kind 8915-F replaces Kind 8915-E, which was used to report coronavirus-related distributions and different certified 2020 catastrophe distributions acquired from retirement plans in 2020 (in addition to 2020 repayments of these distributions). Varieties 8915-B, 8915-C, and 8915-D (regarding certified 2017, 2018, and 2019 disasters, respectively) have been up to date for 2021. The 2021 revision is the final revision of Kind 8915-B. Kind 8915-A (certified 2016 disasters) has not been up to date; the 2020 revision is the final model of that kind.
Kind 8915-F is significantly completely different from earlier kinds within the sequence. It consists of new strains for indicating the tax yr for which the shape is being filed, the calendar yr wherein the catastrophe occurred, and the FEMA quantity for the catastrophe. (House is offered for a number of disasters in the identical calendar yr.) There’s a separate checkbox if the catastrophe is the coronavirus pandemic. The shape is referred to utilizing the tax yr and catastrophe yr checked—e.g., a “2021 Kind 8915-F (2020 disasters)” can be a kind filed for the 2021 tax yr that pertains to disasters that occurred in 2020. To assist filers decide which strains to finish, the primary web page of the shape consists of two flowcharts—one for filers whose solely catastrophe is the coronavirus pandemic and the opposite for all different filers. The directions embody an appendix offering comparable help (overlaying 2021 by way of 2024 reporting for 2020 disasters) and a separate appendix itemizing certified 2020 disasters (with their FEMA numbers and incident durations).
Kind 8915-F has 4 elements: Half I determines the portion of a person’s whole retirement plan distributions which may be entitled to particular disaster-related tax therapy. Half II is used to report certified catastrophe distributions from retirement plans (aside from IRAs) and decide the quantity topic to tax for the yr; Half III stories this data for IRA distributions. Half IV determines the tax penalties of distributions taken for the acquisition or development of a predominant dwelling that was not bought or constructed because of the catastrophe, adjusted for repayments. Half IV applies just for specified disasters (not together with the coronavirus pandemic).
Kind 8915-F can solely be utilized in reference to coronavirus-related distributions if these distributions had been claimed on a 2020 Kind 8915-E (coronavirus-related distributions can’t be made after December 30, 2020). The Kind 8915-F directions specify which parts of the dialogue don’t apply if a person’s solely certified catastrophe is the coronavirus.
EBIA Remark: For taxpayers eager to make the most of statutory catastrophe reduction, finishing Kind 8915-F will take time and a focus, even with the assistance of the flowcharts, tables, and examples offered within the kind and directions. The shape’s complexity displays the complexity of the catastrophe reduction guidelines, which is magnified when addressing a number of disasters. Monitoring a number of disasters is difficult even for the IRS: In an earlier model, the appendix itemizing certified 2020 disasters mistakenly included a number of 2021 disasters. And the directions’ present listing of reportable occasions consists of an apparently incorrect reference to a “Washington (8593-DR-WA) catastrophe.” (The IRS could have meant to discuss with the late-2020 Alaska (4585-DR-AK) catastrophe mentioned later within the directions.) This confusion could also be cleared up in a later revision of the directions, or by the 2021 model of Publication 575, which is anticipated quickly. Though employers and plan directors aren’t answerable for submitting the Kind 8915-series, they could discover it helpful to be accustomed to the kinds and their operation. For extra data see EBIA’s 401(okay) Plans guide at Sections XII.G.2 (“Catastrophe-Associated Distributions”), XV.H (“Particular Hardship Guidelines for Catastrophe Reduction”), and XVI.N (“Distributions: Participant Loans: Particular Guidelines for Catastrophe Reduction”).
Contributing Editors: EBIA Employees.