Retroactively claiming the Advanced Premium Tax Credit for 2020 on an amended tax return

[Xtermy]

Hello,

In 2019 I didn't have enough income to qualify for the Advanced Premium Tax Credit for 2020 when I filed my 2020 ACA coverage application. As a result, I paid for my 2020 ACA premiums in full, and I also didn't have any cost-sharing reductions. Therefore, while I did receive a Form 1095-A for 2020, there were no APTC payments on it (in Part III, column C), and no Form 8962 was issued to me, either.

However, in 2020 I did in fact have enough income, which could've qualified me for this credit and cost reductions. I therefore wanted to know if there is any way to retroactively claim the APTC for 2020 (on an amended 2020 tax return), if I first didn't have enough income to qualify for it in a prior year (2019), but then ended up having enough such income in the actual following year (2020).

Right now I can only attempt to itemize and deduct my out-of-pocket premium payments, as well as medical and dental expenses, but all these put together don't rise above the standard deduction in any case. I also called the ACA Marketplace, but they didn't know the answer to the question above.

Any help would be greatly appreciated.

Thank you very much.

[MaryK4]

Yes you can file an amended return to claim the Premium Tax Credit that you did not get in advanced.  Note there is a three year time limit so file as soon as you can.  See How do I amend my federal tax return for a prior year?  

[Xtermy]

Hello MaryK4,

I very much appreciate your answer! I actually didn't think that this would be possible to do retroactively.

However, the article that you linked to doesn't offer specific instructions as to how to claim this particular credit retroactively. I tried amending my return and looking for this option myself, but I don't see the option to do that in the Medical Expenses section. Therefore, where can I get step-by-step instructions for this particular case?

Thank you very much.

[MaryK4]

Did you file your 2020 tax return with TurboTax?  You have to file an amended return to claim the credit, so what you need to do is sign in to access your 2020 return and indicate that you need to amend (like in the instructions) then you will go through the TurboTax 1095-A section and enter your 1095-A information.  TurboTax calculates the credit for you.  Let me know if this makes more sense or if I can help more.  @Xtermy 

[Xtermy]

Hello again MaryK4,

Yes, it makes perfect sense, and I've found the exact section where I need to enter the information. Thank you so much!

However, I have the following problem: I started being on an ACA plan in late 2019, and continued to be in one until early 2023. In 2019-2020 I wasn't getting financial assistance. In 2021-2022 I did get such assistance.

I have therefore received 1095-A forms for 2021 and 2022, and a 1095-B for 2019, for that partial Marketplace enrollment in 2019. For 2020 I unfortunately cannot find the form (either 1095-A or 1095-B, nothing).

I believe that I got a 1095-B instead of a 1095-A in 2019 because I wasn't getting premium assistance. And the letter came directly from my insurance company, and not from ACA, even though it was an ACA plan.

I have already called the ACA, and they can't find my application for 2020, which also means that they don't see a 1095-A form for that particular year. They therefore told me to contact the insurance company (which I will). However, even IF the insurance company manages to find my 2020 1095 form, if it then ends up being 1095-B instead of 1095-A, won't this mean that I wouldn't be able to retroactively claim the APTC, regardless of fully paying the premiums out-of-pocket? (Since the required information such as SLCSP, marketplace identifiers and marketplace policy numbers will be missing from a 1095-B?)

Thank you very much.

[MaryK4]

Oh no, that is correct if it is a 1095-B it was not a Marketplace plan and does not qualify for the Premium Credit- if you get the form, post back here- I will keep an eye on it.  

[Xtermy]

Understood, much appreciated. I'll update as to which form (if any) I'll be able to get for 2020.

So just to confirm - if I don't get a premium subsidy for an ACA plan, then do I get a 1095-B from the insurer, instead of a 1095-A from the ACA, even if it was an ACA plan? (Or does it not make sense? Because that's what seems to have happened for me for 2019)

My other question is whether I'll have 3 years to claim a tax refund from the date I actually filed my 2020 tax return (October 15th, 2020), or from the original filing deadline? (this IRS article seems to suggest that it's generally from my actual filing date: Refund Statute Expiration Date (RSED))

If it's the actual filing date, then I should hopefully still have several months to get all this sorted out...

Thank you very much for the continuing assistance.

[AliciaP1]

No, if you were covered under a plan that qualifies for the Premium Tax Credit (what you are calling the premium subsidy) you would receive a 1095-A.  If you received a 1095-B or 1095-C you do not need to enter it for your tax returns because there is no additional benefit you can claim.

The amendment filing deadline is 3 years from the date you filed your return.

Per the IRS:

Generally, to claim a refund, you must file Form 1040-X within 3 years after the date you filed your original return or within 2 years after the date you paid the tax, whichever is later. Returns filed before the due date (without regard to extensions) are considered filed on the due date, and withholding is deemed to be tax paid on the due date.

@Xtermy