I have Schwab IRA's and they do not send out a 5498 in May showing FMV if no contributions are made nor do they send out in January a FMV statement for my IRA's. I have spillover and throwback dividends (dividends paid in early 2025 that were declared in 2024). IRS makes it clear that the 1099DIV must have the dividend reported taxable in the year it was declared, not when it is paid but I cannot find where IRS states that the IRA FMV must include dividends paid in the following year. Schwab states to use the year end account statement which does not include the spillover or throwback dividends for the FMV but also has a fine print note:
Your fair market
value and RMD calculated amount may need to be adjusted to include any transfers, rollovers,
recharacterized contribution or security pricing correction after 12/31 of the prior year. But, there is no way to verify what Schwab is sending to IRS for the FMV. The statement also states not to use the statement for tax purposes but certainly using the statement to derive the RMD from the statement FMV would be just that.
I cannot find where IRS states that the broker must send by January 31st the final updated FMV. I cannot find where IRS states that Schwab does not have to send a 5498 if no contribution is made. To me, the 1099 / 5498 instructions are clear that I am entitled to an updated FMV that is being sent to IRS. I cannot find where IRS does or does not require a spillover or throwback dividend be included in the IRA FMV.
