IRS Updates Acts that May Be Postponed Due to Disaster, Armed Forces Service

The IRS released an updated list of tax-related time-sensitive acts that may be postponed due to federally-declared disasters or service in the Armed Forces in Revenue Procedure 2018-58.

The revenue procedure itself does not provide for any postponements. Instead, it states that postponements under Internal Revenue Code section 7508A (referring to disasters) are contingent on IRS notices or other guidance, but that postponements of acts listed under Internal Revenue Code section 7508 (referring to service in the Armed Forces) is allowed regardless of whether the IRS issues notices or other guidance. As the regulations stand now, when an individual qualifies for relief by virtue of serving in the Armed Forces in a combat zone, the time for performing tax-related acts is not postponed. Revenue Procedure 2018-58 contains a list of these acts so that individuals serving in combat zones may also receive a postponement.

A partial list of notable acts that are cited in the revenue procedure follows.

Business and Individual Tax Issues

  • Indirect rollover timing (60-day requirement) from 529 plans, ABLE accounts, Coverdell ESAs

  • Distribution of excess contributions from 529 plans

  • Filing of Form 5498-QA with the IRS

  • Distribution of excess contributions from Coverdell ESAs

  • Filing of Form 5498-ESA with the IRS

Employee Benefit Issues

  • Timing requirements for loan repayments

  • Substantially equal periodic payments timing

  • IRA contribution timing

  • Indirect rollover timing (60-day requirement) from Archer MSAs, HSAs, and qualified retirement plans

  • Filing of Form 5498-SA with the IRS

  • RMDs from qualified plans

  • Distribution of qualified plan excess deferrals, excess contributions, and excess aggregate contributions

  • Plan loan offset timing

  • Qualified plan, SEP, and SIMPLE IRA contribution deadlines

  • Filing of Form 5498 with the IRS

  • Recharacterization deadlines/timing

  • Permissible withdrawal timing for EACAs and QACAs

  • Distribution of IRA excesses

  • Form 5500, 5500-SF, Form 5500-EZ, and Form 8955-SSA filing deadlines

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