Form 8915-F (Qualified Disaster Retirement Plan Distributions and Refunds) and Instructions (Revised January 2023)



The IRS has issued revised Form 8915-F and Instructions for Individual Taxpayers to Report Retirement Plan Distributions Due to Qualified Disasters and Refunds of Disaster Distributions. Form 8915-F is a “forever form,” designed to be used for distributions for qualified disasters in 2020, 2021, and after, and for each income reporting and refund year of those distributions (see our Checkpoint article).

The revised Form 8915-F reflects several changes to 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 beginning after 2020 does not have a set end date based on the year of the disaster, but must be calculated separately for each qualified disaster. Taxpayers must calculate the qualified disaster distribution end date for their disaster to determine if their distributions are qualified disaster distributions. Under the SECURE Act 2.0, the qualified disaster distribution period for a qualified disaster begins on the date the disaster begins and ends 179 days after the later of: (1) the disaster start date; (2) the date of the disaster declaration; or (3) December 29, 2022.

Line 1a has been completely revised to help taxpayers identify the correct dollar amounts of distributions available for the current year. If a taxpayer verifies 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 help taxpayers determine the total amount of qualified disaster distributions made from all retirement plans.

For 2021 and later qualified disasters, taxpayers are directed to use the FEMA declared disasters web page to identify if 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 helpful to become familiar with the form and how it works. 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 the Form 8915-F web page. For more information, see EBIA’s 401(k) Plans manual at Sections XII.G.2 (“Disaster-Related Distributions”), XV.H (“Disaster Relief Special Hardship Rules”) and XVI.N (“Distributions: Loan Participant: Special Rules for Disaster Relief”).

Contributing editors: EBIA staff.

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