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What if there were excess distributions from the 529 plan?

My son has $750 in earned income and $200 in excess 529 distributions.  That total is below the $1100 threshold.

 

I went through the IRS do-i-have-to-file wizard.  The answer appears to turn around my response to, "Are you liable for an additional tax on a qualified plan, including an Individual Retirement Arrangement (IRA), or other tax-favored account, in 2020?"

 

If I answer yes, it says he has to file.  If I answer no, it says he needn't.

  • The 529 plan is a tax-favored account. I think.
  • The details on the wizard refer to publications with titles about IRA and about "Health Savings Accounts and Other Tax-Favored Health Plans". (I added the underline.)

529 plans are neither IRA nor Health Plans, so I conclude that the mere fact he has a small excess distribution from the 529 plan does not require filing a tax return.

 

Does that sound right to you?  Does $200 of excess 529 distribution (with $49 of the distribution attributable to *income*) compel filing a return?