COVID Distribution Return Date

Hello-

Client is returning a COVID distribution to their account. Would it be considered returned when placed in the mail to the custodian, when the custodian has processed, or otherwise?

Thank you!



Most likely options for the custodian to adopt would be the date received by the custodian or in some cases they might use the postmark date like some do for regular IRA contributions. But the custodian does not know if an extension was filed for the prior year return or the date of the CRD, and they just report the repayment on a 5498 for the calendar year the repayment was received. Therefore, that leaves much of the repayment reporting on Form 8915 to be resolved between the client and the IRS.

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