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The Once-in-a-Lifetime IRA Transfer to an HSA

Take a once-in-a-lifetime distribution tax-free from your traditional IRA. Maximize your tax savings.The Tax Code is riddled with esoteric deductions even many tax professionals are unaware of. So rare is the topic of today’s discussion that I never once in my career had a client use what I am about to point out.

Before you get too excited, know that just because you can do something doesn’t mean you should. Only under a unique set of circumstances would using this tax strategy be beneficial so read carefully. You only get one shot at this strategy because it is only allowed once in your lifetime. 

It’s called a Qualified HSA Funding Distribution (QHFD). In short, a QHFD allows you to fund your HSA with pre-tax monies in a traditional or Roth IRA or inactive SEPs and SIMPLEs. 

Let’s dig into the details before we discuss when it is appropriate to use your once-in-a-lifetime election and when it isn’t. 

 

Characteristics

  1. You must still qualify for an HSA contribution when using an QHFD. This means you must have an HSA qualified health insurance plan with applicable high deductibles.
  2. You must remain eligible for an HSA for 12 months or longer after making a QHFD. If you are not HSA compliant for at least 12 months after the QHFD you must include the distribution in  your income along with any penalty if under age 59 1/2.
  3. You must use a trustee-to-trustee transfer. You are not allowed to take the money out and then put it in the HSA. (Well, actually, you can, but the IRA distribution would be included in income — along with penalties if under age 59 1/2. But you would get the HSA deduction, offsetting the IRA distribution included in income.)
  4. A QHFD does not increase the amount you can put in an HSA for that year. Contribution limits still apply.
  5. You also do not get an HSA deduction for funds transferred from an IRA; the money is already pre-tax.
  6. An inherited IRA can be used for a QHFD.
  7. The QHFD lowers your RMD by the amount transferred for the year of the transfer.
  8. There is no 10% early distribution penalty with a QHFD as long as you follow the 12 month rule and qualify for an HSA.
  9. This strategy can only be used once-in-a-lifetime per taxpayer.

 

Why Would Anyone Do This?

Learn how to use your once-in-a-lifetime tax election to transfer money tax-free from a traditional IRA to an HSA.When you think about this for awhile it might seem a counter-productive tax move. (We will discuss instances where the QHFD is advantageous later.) You are not allowed a larger contribution to the HSA with this strategy and you get no additional deduction either.

Roth IRAs are a non-starter. rIRAs are already growing tax-free so moving money from a rIRA to an HSA provides no additional advantage with the added restrictions, such as the 12 month requirement listed above and a QHFD is limited to pre-tax dollars.

SEPs and SIMPLEs must be inactive to employ this strategy. This means contributions are no longer added to the account. The IRS is silent on how long an account must go without contributions to be considered inactive or if the SEP or SIMPLE can become active in the future.

There are a number of situations where the QHFD is superior to just funding the HSA and getting an additional deduction:

  1. You don’t have the money to fully fund your HSA this year. Since you would not fund your HSA anyway you end up with additional cash in the HSA that now grows tax-free instead of tax-deferred (I assume throughout this post that you use a QHFD from a tIRA to an HSA.) 
  2. If your tIRA is large and significant RMDs loom, any tax-free distribution from the tIRA is advantageous. It also lowers the RMD by the amount of the QHFD for that year.
  3. This strategy is better than taking an IRA distribution and paying the penalty (if under age 59 1/2) and then contributing to the HSA.
  4. You want (or your facts and circumstances dictate) to turn tax-deferred growth into tax-free growth. Remember, a tIRA grows without tax until withdrawn; an HSA grows tax-deferred and if used for qualified medical expenses and/or Medicare premiums the money comes out tax-free at any age.
  5. High medical bills make it difficult to fund the HSA and access to HSA funds are needed for uncovered medical expenses.

There are other reasons to use a QHFD, based on facts and circumstances and personal preference. Personally, I think people with large IRAs might want to employ this tax strategy and these that lower their future RMDs

 

Gaming the System

For 2019 you can contribute $3,500 for individual health plans and $7,000 for family plans into an HSA. (Those 55 and older can add another $1,000 to their HSA as part of the catch-up provision.)

There is a little-known tax strategy that allows you to transfer money from your traditional IRA to an HSA tax-free and penalty-free. Learn how this tax strategy affects you.In The Wealthy Accountant private group on Facebook a member asked about this tax strategy. Since the issue never arose in my office I wanted to dig a bit before answering and then couldn’t find the original post on Facebook (fingers crossed the person who asked finds this post.)

His question was about gaming the QHFD to double the tax benefit by transferring two years of contributions by making the contribution in the cross-over months (up to April 15th of the following year without consideration for extensions). He wanted to know if he could make, say, a $14,000 family plan contribution: half for last year and half for this year.

He did his research and found the IRS and all other sources silent on the issue. I found the same thing.

However, after I thought about it for awhile I realized this would NOT work. The once-in-a-lifetime QHFD would have to go on two tax returns if you doubled the transfer during the cross-over months which would make the second election disqualified. Sorry. But I like the way you think.

 

Round Up

The concept is rather simple. The benefits are fairly small, but worth it if your situation dictates. Those facing large RMDs and those seeking to turn a small portion of their tax-deferred tIRA into tax-free growth in an HSA will find the most value.

Now I need to make a confession. When I first saw the question in the private Facebook group I thought the person posting was smoking something. I never heard of such a tax strategy (or it went in this ear and out the other.) I had to look it up to believe.

If you plan on using this strategy don’t get mad at your tax professional if they never heard of this. Just tell them to go to their software’s Special Situations tab on the 1099-R screen. All they need to do is add one simple number (the amount transferred to the HSA up to the contribution limit).

If you run across a tax strategy you never heard of before be sure to leave a comment. If possible I will leave a short answer. And, as in this situation, I may flesh it out a bit more in a post. 

Many of these strategies provide only a small tax benefit. Added together with several other small tax strategies can accumulate to serious tax savings. 

Hope this one works for you or at least gets you thinking about another tax saving strategy that improves your financial situation.

 

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Medi-Share is a low cost way to manage health care costs. As health insurance premiums continue to sky rocket, there is an alternative preserving the wealth of families all over America. Here is my review of Medi-Share and additional resources to bring health care under control in your household.

QuickBooks is a daily part of life in my office. Managing a business requires accurate books without wasting time. QuickBooks is an excellent tool for managing your business, rental properties, side hustle and personal finances.

cost segregation study can reduce taxes $100,000 for income property owners. Here is my review of how cost segregation studies work and how to get one yourself.

Worthy Financial offers a flat 5% on their investment. You can read my review here. 

Keith Taxguy

9 Comments

  1. Robert on April 28, 2019 at 9:59 pm

    Is there a $$ limit to the amount of transfer allowable?
    I saw your follower was seeking an additional $7k, but didn’t read if you can transfer any amount.
    I would love to fund our HSA with additional dollars as we’ve only been eligible for the last several years.

    • Keith Taxguy on April 29, 2019 at 8:40 am

      You are limited by the contribution limit: $3,500 for an individual health insurance plan; $7,000 for a family plan (plus $1,000 for those 55 and older). If you exceed the limit you will face a penalty for an excess contribution.

      • Robert on April 30, 2019 at 9:03 am

        Ok, just so I’m clear. This would allow you to fund your HSA account with retirement dollars (IRA, Roth, etc) vs. current available cash. So, the best you can do for a family is the $7,000 max and the real benefit is 1) your HSA is funded, 2) all new investment returns would be tax free (as long as it’s used for medical) and 3) it reduces your RMD. Is that about right?

        • Keith Taxguy on April 30, 2019 at 9:06 am

          That’s the extent of it, Robert. Makes for a short blog post.

          The savings are small. Some people love the idea; others hate it (just read some of the other bloggers writing about it). I think it is on a person-by-person basis.

  2. Mike on April 29, 2019 at 5:45 am

    If you are married filing jointly can this be done in 2 tax years using IRA account of each spouse in a given tax year?

    • Keith Taxguy on April 29, 2019 at 8:46 am

      The Code says this is “per person”. The question is: Does this apply to individual and family plans or just individual?

      I think it means per person for either. The IRS has done nothing to provide guidance on this. My interpretation is that both parties of a married couple can take the once-in-a-lifetime break for a family plan. This means one can take the election on a family plan ($7,000 for 2019) and the other next year. The election is made on the 1099-R screen so it is at the individual level.

      What I think does not work is the doubling up per person by making two years of contributions before April 15th.

  3. Cindy on April 29, 2019 at 11:31 am

    So happy to learn of this as I’m in the very mode of reducing my balances which will fall under the RMD, in anticipation of my retirement in 2.5 years. WOOHOO!!!
    Though not big money, it’s money none-the-less.
    Thank you, Thank You, THANK YOU

  4. Paul Neiffer, CPa on April 29, 2019 at 1:05 pm

    If you are on Medicare this will not work since HSA are not allowed if on Medicare. You would want to do this before starting Medicare. It will not work for very many RMD due to this.

    • Keith Taxguy on April 29, 2019 at 1:24 pm

      Correct, but you can use it years later to pay Medicare premiums.

      As for the RMD: It works best with inherited IRAs that do require an RMD, regardless of age.

      I was less than clear about this in the post. Thanks for pointing it out, Paul.

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