Form 8915-F is used to report qualified disaster distributions (QDDs) from eligible retirement plans, including IRAs, 401(k)s, 403(b)s, and governmental 457 plans, when a taxpayer is affected by a federally declared disaster. The form is also used to report income inclusion over time and any allowable repayments of those distributions.
Form 8915-F applies to qualified disaster distributions for 2020 disasters (including COVID-related rules that carry forward) and for 2021 and later federally declared disasters designated by the IRS. It is a “permanent” form used for both the year of distribution and subsequent years of reporting income or repayments.
Qualified Disaster Distribution Requirements
A distribution qualifies only if it is made because of a federally declared major disaster (as declared by FEMA) and the taxpayer meets the requirements defined in the specific disaster legislation or IRS guidance.
A qualified disaster distribution may be made from:
- Qualified retirement plans (401(k), 403(b), pension plans, governmental 457 plans)
- Traditional IRAs (and similar IRA types)
A distribution is only treated as qualified if it is made during the IRS-defined “qualified disaster distribution period” for that specific disaster and is properly reported on Form 8915-F.
Income Reporting Options
Taxpayers may choose one of the following options:
• Three-year inclusion:
The taxable portion of the distribution is generally included in income evenly over three years, beginning with the year of the distribution (typically 1/3 per year).
• Elect full inclusion:
The taxpayer may elect to include the entire distribution in income in the year received.
The election is made on Form 8915-F and applies separately for each disaster.
Repayment Rules
Taxpayers may repay all or part of a qualified disaster distribution to an eligible retirement plan or IRA within the repayment period defined for that disaster (generally up to 3 years and 1 day after the distribution, depending on rules in effect).
Key rules:
- Repayments reduce taxable income previously reported
- If income was reported in earlier years, amended returns (Form 1040-X) may be required
- Repayments restore the tax treatment as if the distribution had not occurred, to the extent allowed under IRS timing rules
Limitations
The maximum amount that can generally be treated as qualified disaster distributions is:
- Up to $22,000 per disaster per taxpayer for 2021 and later disasters (as provided under SECURE 2.0 rules, subject to IRS guidance)
- Different limits apply for 2020 COVID-related distributions (which were governed by CARES Act rules)
Each disaster has its own eligibility window based on IRS designation and FEMA declaration dates.
Additional Tax Considerations
Qualified disaster distributions:
- Are generally not subject to the 10% early withdrawal penalty under IRC §72(t)
- May still require reporting of penalty exceptions on Form 5329 when applicable, depending on the type of distribution and how the return is prepared
- Must still be included in income unless excluded under the 3-year spread or repayment rules
Source:
Form 8915-F
Disclaimer: Always verify details with current IRS forms, instructions, and your state’s Department of Revenue. For complex situations, consult a CPA or tax attorney.