The IRS instructions for boxes 13a, 13b and 13c are
set forth below. These are the instructions for the IRA
custodian.
Box 13a. Postponed Contribution
Report the amount of any postponed contribution
made in 2017 for a prior year. If contributions were
made for more than 1 prior year, each prior year’s
postponed contribution must be reported on a separate
form. Report the amount of a late rollover contribution
made during 2017 and certified by the participant.
See Rev. Proc. 2016-47 is available at
www.irs.gov/irb/2016-37_IRB/ar09.html. If the participant
also has a postponed contribution, use a separate
Form 5498 to report a late rollover.
CWF Discussion. Report the amount of a late 2017
rollover contribution if the individual furnished the
IRA custodian with his/her self-certification. A separate
Form 5498 with box 13a is to be completed if their
person also made a postponed contribution. The
instructions do not discuss the possibility of two late
rollovers. We believe the IRS instructions do discuss
that two separate 5498 forms should be filed. The IRS
instructions do discuss that there must be separate
5498 forms filed if there were postponed contributions
for more than one prior year.
Box 13b. Year
Enter the year for which the postponed contribution in
box 13a was made. Leave this box blank for late
rollover contributions.
CWF Discussion. This box is left blank if the contribution
being reported in Box 13a is a late rollover
contribution.
Box 13c. Code
Enter the reason the participant made the postponed
contribution.
For participants’ service in a combat zone, hazardous
duty area, or direct support area, enter the
appropriate executive order or public law as defined
under Special reporting for U.S. Armed Forces in designated
combat zones, earlier.
For participants who are “affected taxpayers,” as
described in an IRS News Release relating to a federally
designated disaster area, enter FD.
For participants who have certified that the rollover
contribution is late because of an error on the part of a
financial institution, death, disability, hospitalization,
incarceration, restrictions imposed by a foreign country,
postal error, or other circumstance listed in Section
3.02(2) of Rev. Proc. 2016-47 or other event beyond
the reasonable control of the participant, enter C.
CWF Discussion. A “C” is to be inserted in this box
if the individual has self-certified that his or her
rollover was rolled over after the 60 day limit for one
of the events set forth in Revenue Procedure 2016-47.
The IRS also furnishes “instructions” to the individual
on the reverse side of Copy A of Form 5498. Set
forth below are the instructions for boxes 13a, 13b
and 13c.
Box 13a. Shows the amount of a late rollover contribution
made in 2017 and certified by the participant,
or a postponed contribution made in 2017 for a prior
year.
Box 13b. Shows the year to which the postponed
contribution in box 13a was credited. If a late rollover
contribution is shown in box 13a, this box will be
blank.
Box 13c. For participants who made a postponed
contribution due to an extension of the of the contribution
due date because of a federally designated disaster,
shows the code FD.
For participants who serviced in designated combat
zones, qualified hazardous duty areas, or in direct
support areas, shows the appropriate code. The codes
are: EO13239 for Afghanistan and associated direct
support areas, EO12744 for the Arabian Peninsula
areas, and EO13119 (or PL106-21) for the Yugoslavia
operations areas. For additional information, including
a list of locations within the designated combat
zones, qualified hazardous duty areas, or direct support
areas, see Pub. 3. For updates to the list of locations,
go to www.irs.gov/form 5498.
For a participant who has used the self-certification
procedure for a late rollover contribution, shows the
code SC.
CWF Discussion: These instructions inform the individual that he or she made his or her rollover after the
60 day deadline, but the IRA custodian accepted the
rollover contribution because he or she self-certified
that one of the exceptions as listed Revenue-Procedure
2016-47 was met. The individual will want to consider
if he or she should furnish additional information at
the time the return is filed explaining why equity and
fairnesss means he or she qualified for a new rollover
period or if he or she should wait for the IRS to contact
him/her and furnish additional information at that
point in time. The instructions for lines 15a and 15b
should be reviewed for additional IRS guidance on the
proper reporting of a rollover contribution.
Admittedly the IRS’ announcement in August of its
new self-certification rollover procedure left the IRS
little time to create a procedure for an IRA custodian
to report that an IRA account holder who had self-certified
his or her 2017 rollover because he or she
missed the 60 day deadline for one of the reasons set
forth in Revenue Procedure 2016-47. Note that this
special procedure only applies with respect to missed
rollovers into an IRA on account of missing the 60 day
limit. It does not apply to missed rollovers on account
of the 60 day limit. It does not apply to missed
rollovers on account of the 60 day rule into a qualified
plan.
Also note, there is no discussion of how an IRA custodian
and/or the IRA account holder is to report a
late 2016 IRA rollover which the individual self-certified.
CWF’s recommendation is that the tax payer
should attach a copy of his/her self-certification as furnished
to the IRA custodian with a note of explanation.