Forms, forms and more forms | Ed Slott and Company, LLC

Forms, forms and more forms

Hello Alan,

I'm sure you've covered these topics in previous posts but I'm hoping you won't mind addressing my particular situation.
I took two RMDs earlier in the year, $4275 (with $525 tax withheld) from a TIRA and $3000 from an annuity IRA (no tax withheld). I rolled back the entire $4275 to the TIRA but elected to keep the $3000 annuity IRA distribution.

As fate would have it I found it necessary to withdraw a $46000 (no tax withheld) CRD from the TIRA. Baring no unforeseen circumstances I intend to take my 2021 RMD ($12000-$1800 tax=$10200) prior to filing my 2020 taxes and apply that amount toward repaying the CRD.

My question is what forms with what amounts can I expect to receive from the respective financial institutions? And what forms with the required amounts on which lines (including the 1040SR) do I complete to report this to the IRS?

Thank you for your assistance.

  • Your 1099R forms for these distributions will show Code 7, same as without the special provisions. However, you will have to file Form 8915 E (not yet released by the IRS) to report the CRD distributions, and your choice to report the income entirely in 2020 or 1/3 each year 2020-2022,  and any repayments of those distributions according to when they are actually repaid. Gross amounts distributed will go on line 4a and net taxable amounts on 4b of either Form 1040 or 1040 SR.
  • Rollovers of 2020 RMDs will be reported on those same lines like ordinary rollovers. The one you did not roll back will have the taxable amount on 4b. 
  • When you repay a CRD, you must advise the receiving IRA custodian that the deposit is a CRD repayment, and they will issue Form 5498 by late May reporting a repayment with an IRS assigned repayment code in Box 14d.  Any portion of your CRD repaid by your filing due date including extensions for your 2020 return will reduce the taxable income for 2020. If you repay later than that due date, you will have to file a 8915 for 2021 as well. Consider this advice tentative pending the release of Form 8915 E and instructions for it's use by the IRS. That may be a few months away. 
  • If you have any IRA basis (Form 8606), you will also have to file that form to calculate the taxable portion of your taxable distributions (both RMDs and CRDs).  If the reporting gets too confusing you may need to use a tax preparer to file your return. 

Alan, thanks for your sage advice.  If form 8915E is as confusing as the C and D versions I probably will have to hire someone.

It will probably be about the same.  Have you filed an 8915 before as a disaster distribution?  If so, how did it go?

No, thank goodness I've never been affected by any disaster until now.  I checked out 8915 versions on the IRS web site.  I like to be prepared.


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