Postponed Deadlines for Time-Sensitive Acts for Victims of Colorado Wildfires & Straight-Line Winds

(January 4, 2022) “Affected taxpayers" who are victims of certain federally declared disasters are eligible for postponed deadlines for the completion of eligible time-sensitive acts, many of which are related to IRAs, employer plans, HSAs, or Coverdell ESAs, when the original deadline falls within a given time period. On January 3, 2021, the IRS issued CO-2022-01 to provide “affected taxpayers” of the Colorado wildfires and straight-line winds relief with postponed May 16th deadlines for the completion of certain time-sensitive acts many of which are related to IRAs, employer plans, HSAs, or Coverdell ESAs. Under the relief, time-sensitive acts referenced in notice with a due date to be performed on or after December 30, 2021, and before May 16, 2022, are postponed until May 16, 2022. The May 16, 2022, postponed deadline includes the deadline for making 2021 IRA and HSA contributions. As a result, affected taxpayers of the Colorado wildfires and straight-line winds will have until May 16, 2022, to make 2021 IRA, HSA and Coverdell ESA contributions.

Affected Taxpayers Currently Eligible for Postponed Deadlines

The chart below summarizes recent disaster areas (as of January 3, 2022),  in which affected taxpayers qualify for postponed time periods to complete eligible time-sensitive acts. Up-to-date details of who is considered an affected taxpayer for each declaration can be found here.

Disaster Area Deadlines During this Time
Period
Postponed
Deadline to 
Complete Acts
California Wildfires On/after July 14, 2021, 
and before January 3, 2022
January 3, 2022
Tennessee Severe Storms 
and Flooding
On/after August 21, 2021,
and before January 3, 2022
January 3, 2022
Louisiana Hurricane Ida On/after August 26, 2021,
and before January 3, 2022
January 3, 2022
Mississippi Hurricane Ida On/after August 28, 2021,
and before January 3, 2022
January 3, 2022
Pennsylvania Hurricane Ida On/after August 31, 2021,
and before January 3, 2022
January 3, 2022
New Jersey and New York
Hurricane Ida
On/after September 1, 2021, and before January 3, 3022 January 3, 2022
Connecticut Hurricane Ida On/after September 1, 2021,
and before January 3, 2022
January 3, 2022
Alabama Severe Storms and Flooding On/after October 6, 2021,
and before February 28, 2022
February 28, 2022
Kentucky Storms On/after December 16, 2021,
and before May 16, 2022
May 16, 2022
Illinois Tornadoes On/after December 16, 2021,
and before May 16, 2022
May 16, 2022
Tennessee Tornadoes On/after December 16, 2021,
and before May 16, 2022
May 16, 2022
Arkansas Severe Storms and Tornadoes On/after December 16, 2021,
and before May 16, 2022
May 16, 2022
Colorado Wildfires and Straight-Line Winds On/after December 30, 2021,
and before May 16, 2022
May 16, 2022

Time-Sensitive Acts

The time-sensitive acts identified 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 these timeframes may include but are not limited to the following transactions.

IRAs

  • Make Traditional and Roth IRA contributions for tax year 2021
  • File Form 1099-R with the IRS
  • Provide to IRA owners and beneficiaries copy of Form 1099-R
  • Provide IRA owners with RMD statements
  • Provide IRA owners and beneficiaries Fair Market Value Statement
  • Withdraw required minimum distributions
  • Determine an employee’s designated beneficiaries in the year following the employee’s death (certain timing requirements apply)
  • 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
  • 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

HSAs

  • Make HSA contributions for tax year 2021
  • Complete a 60-day HSA-to-HSA rollover
  • File Form 1099-SA with the IRS
  • Provide to HSA owners and beneficiaries copy of Form 1099-SA

Coverdell ESAs

  • Make Coverdell ESA contributions for tax year 2021
  • Complete a 60-day ESA-to-ESA
  • File Form 1099-Q with the IRS
  • Provide to Responsible Individuals and Designated Beneficiaries copy of Form 1099-Q

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”

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