IRS Issues Revised Form 8915-F for Reporting Qualified Disaster Distributions and Repayments
Form 8915-F (Qualified Disaster Retirement Plan Distributions and Repayments) and Instructions (Rev. Jan. 2023)
Form
Instructions
The IRS has issued revised Form 8915-F and Instructions for individual taxpayers to report retirement plan distributions due to qualified disasters and repayments of disaster distributions. Form 8915-F is a “forever form,” designed to be used for distributions for qualified 2020, 2021, and later disasters, and for each year of reporting income from and repayment of those distributions (see our Checkpoint article).
The revised Form 8915-F reflects several changes in the law made by the SECURE 2.0 Act. For example, under the SECURE 2.0 Act, the period for making qualified disaster distributions for qualified disasters that begin after 2020 does not have a set ending date based on the year of the disaster but must be separately calculated for each qualified disaster. Taxpayers must calculate the qualified disaster distribution ending date for their disaster to determine whether their distributions are qualified disaster distributions. Under the SECURE 2.0 Act, the qualified disaster distribution period for a qualified disaster commences on the date the disaster begins and ends 179 days after the latest of the following: (1) the disaster beginning date; (2) the disaster declaration date; or (3) December 29, 2022.
Line 1a has been completely revised to help taxpayers identify the correct dollar amounts of available distributions for the current year. If a taxpayer checks that a distribution was made for tax year 2021 or later, and the calendar year in which the qualified disaster began was also 2021 or later, the dollar limit is $22,000 per disaster. A new Worksheet 1B is added to assist taxpayers in determining the total amount of qualified disaster distributions made from all retirement plans.
For qualified 2021 and later disasters, taxpayers are instructed to use the FEMA Declared Disasters webpage to identify whether a disaster is a qualified disaster. For prior disasters, the list of qualified disasters was provided in Appendix B in last year’s Instructions.
EBIA Comment: Although employers and plan administrators are not responsible for filing Form 8915-F, they may find it useful to be familiar with the form and its operation. Also, note that the revised form and instructions are dated January 2023, but the IRS has since made additional changes, as reflected in the Instructions’ footer and on the Form 8915-F webpage. For more information see EBIA’s 401(k) Plans manual at Sections XII.G.2 (“Disaster-Related Distributions”), XV.H (“Special Hardship Rules for Disaster Relief”), and XVI.N (“Distributions: Participant Loans: Special Rules for Disaster Relief”).
Contributing Editors: EBIA Staff.
