Postponed Deadlines for IRA/HSA Contributions and Other Time-Sensitive Acts For West Virginia Storm Victims

(June 1, 2021) On May 27, 2021, the IRS issued WV-2021-01 to provide affected taxpayers" who were victims of severe storms and flooding in West Virginia relief with postponed deadlines for the completion of certain time-sensitive acts, many of which are related to IRAs, employer plans, HSAs, or Coverdell ESAs. The relief is similar to the relief that was provided earlier this year to "affected taxpayers" who were victims of the winter storms in Texas, Oklahoma, and Louisiana as well as storms in Alabama, Kentucky, and Tennessee.

The time-sensitive cts identified in the news release that are eligible for the extended deadline include any action listed in either Treasury Regulation 301.7508A-1(c)(1) or Revenue Procedure 2018-58. Some of the time-sensitive acts relating to IRAs, employer retirement plans, HSAs and Coverdell ESAs with a due date that falls within this timeframe include acts performed by individuals (including making IRA and HSA contributions for tax year 2020), while others are acts performed by IRA providers and/or employer sponsored plan, or HSA or Coverdell ESA providers.

Relief Under News Relief WV-2021-01 Under the relief of News Relief WV-2021-01, time-sensitive acts referenced in the news relief (many of which are listed below) with a due date to be performed on or after February 27, 2021, and before June 30, 2021, are postponed until June 30, 2021. This includes IRA and HSA contributions for tax year 2020.

HSAs

  • Make HSA contributions for tax year 2020
  • Complete a 60-day HSA-to-HSA rollover
  • File Form 5498-SA with the IRS
  • Provide to HSA owners an Annual Account Statement which is often satisfied by providing a copy of IRS Form 5498-SA

IRAs 

  • Make Traditional and Roth IRA contributions for tax year 2020
  • Complete rollovers including an IRA-to-IRA 60-day rollover, a 60-day indirect rollover from an eligible employer plan to an IRA, a rollover within 120 days of a first-time home distribution withdrawn from an IRA that meets certain requirements, and a rollover of a wrongful IRS levy of an IRA or employer retirement plan
  • Use IRA distributions within 120 days of the distribution to qualify for the first-time homebuyer early distribution penalty exception
  • Repay qualified reservist distributions
  • Withdraw substantially equal periodic payments from an IRA
  • Make a qualified disclaimer
  • Certain QLAC transactions
  • File Form 5498 with the IRS
  • Provide to IRA owners and beneficiaries an Annual Account Statement which is often satisfied by providing a copy of IRS Form 5498
  • File Form 990-T with the IRS
  • Make SEP and SIMPLE IRA contribution for the 2020 tax year
  • Remove an IRA excess contribution with earnings attributable to avoid the 6% excess contribution penalty
  • Recharacterize a Traditional or Roth IRA contribution

Coverdell ESAs

  • Make Coverdell ESA contributions for tax year 2020
  • Complete a ESA-to-ESA 60-day rollover
  • Remove an ESA excess contribution with earnings attributable to avoid the 6% excess contribution penalty
  • File Form 5498-SA with the IRS
  • Provide to ESA Designated Beneficiary an Annual Account Statement which is often satisfied by providing a copy of IRS Form 5498-ESA

Qualified Plans

  • Make corrective distributions of excess deferrals, excess contributions and excess aggregate contributions
  • Make timely permissible withdrawals of unwanted deferrals under an eligible automatic contribution arrangement (EACA)
  • File form 5500
  • Make plan loan repayments “quarterly or more frequently”
  • Make an indirect rollover of an eligible rollover distribution (ERD)

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