TurboTax is producing a tax year 2025 form 5329 that shows a continuing excess HSA contribution even though I withdrew the excess during the 2025 tax year. The interview never asks me if the excess has been withdrawn. And even though I entered a 1099-SA recording the excess distribution it still lists the amount as excess for 2025.
Here are the details:
The interview never asks if the excess contribution was withdrawn, though. And it doesn’t seem to pick up on the fact that the 1099-SA is the withdrawal. It’s still putting “$19” on line 48 of the 2025 form 5329.
How do I get TurboTax to take the excess off my 2025 return so this stops being carried over?
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The issue is that the HSA process as described by Congress and the IRS is very obscure and uses words in confusing ways. The result is that the HSA process doesn't work the way that most taxpayers think it does. This results in taxpayers thinking that TurboTax is coded wrong, when in fact it is operating correctly.
For example, when you thought that you had withdrawn the excess contribution, you did not do it in the way that the IRS prescribes, so the excess continued to roll on.
This is poorly explained by the IRS (see IRS Pub 969), but once you create an excess that gets carried over, you can't fix it by withdrawing it (but see below). TurboTax tells you that you have an excess, but when you try to withdraw it, TurboTax will say it can't be done, and it is not at all clear why not.
Original Year
When you have an original excess, you have two choices:
* withdraw the excess without penalty ("withdrawal of excess HSA contributions" by the original due date or extension, distribution code of '2')
* roll the excess to next year with the hope that you can use it as a contribution next year
But when you pass the original due date (or extension date), the first option (withdrawal) is gone. After the original due date (or extension date), you now have these choices:
Subsequent Year
* withdraw the excess as a normal distribution (code '1') - this will not only be taxed as ordinary income, but will also be hit with a 20% penalty.
* roll the excess to next year with the hope that you can use it as a contribution next year (but if you have changed insurance carriers or maybe gone on Medicare, it might never be usable again).
So when TurboTax tells you that you have an excess of $19 for 2022, since you have passed the original due date (April 15, 2023), you could do this:
1. If you will have HDHP coverage next year, make sure that you can include the excess as a personal contribution under your Family contribution limit (i.e., reduce the contributions you would have otherwise made).
2. Keep the 1099-SA with its code of '1', change it so that it is not marked as all for medical expenses, then accept the fact that the distribution amount will be added to Other Income on Schedule 1 (1040) and the 20% penalty will also be added to Schedule 2 (1040).
However, you chose to roll the $19 over to 2024 and then 2025, and I assume that you never had HDHP coverage again, so the $19 was never used up.
When you "withdrew" the $19, you told the HSA custodian that it was something like a withdrawal of excess HSA contributions, so they sent you a 1099-SA with the distribution code of '2'. But this is the correct procedure only if you do the withdrawal in the first year (i.e., before the first due date). Unfortunately, in common English, we use "withdrawal" for any removal of dollars from the account, whereas the IRS uses "withdrawal" in a very specific sense - to remove the excess in a timely manner in the year current with the excess (well, up to the original due date of that tax year).
Don't blame the HSA custodian - they don't know any better.
Now that you are beyond the first year (and its original due date of April 15, 2023), you have to proceed to "Subsequent Year" above. You apparently don't have bullet point 2 available to you (using up the rolled over excess as a personal contribution in a future year). So the only method you have available to you to cut off the continuous carrying over of the excess is to take a distribution from your HSA (distribution code of '1') equal to the amount of the excess, and not marking it as used for medical expenses.
This action will result in the excess being add to Other Income on Schedule 1 (1040), as well as a 20% excise tax ("penalty") added to Schedule 2 (1040). But then, the carryover will be done. Such a distribution cuts off any carryover without you making any special entries.
Or is it an issue with the forms themselves?
Line 44 of form 5329 seems like it be populated with the $19 distribution:
But the value of that field is the value of line 16 on form 8889:
And the instructions for that field have you remove the excess from the total distribution which results in the $0 value.
The issue is that the HSA process as described by Congress and the IRS is very obscure and uses words in confusing ways. The result is that the HSA process doesn't work the way that most taxpayers think it does. This results in taxpayers thinking that TurboTax is coded wrong, when in fact it is operating correctly.
For example, when you thought that you had withdrawn the excess contribution, you did not do it in the way that the IRS prescribes, so the excess continued to roll on.
This is poorly explained by the IRS (see IRS Pub 969), but once you create an excess that gets carried over, you can't fix it by withdrawing it (but see below). TurboTax tells you that you have an excess, but when you try to withdraw it, TurboTax will say it can't be done, and it is not at all clear why not.
Original Year
When you have an original excess, you have two choices:
* withdraw the excess without penalty ("withdrawal of excess HSA contributions" by the original due date or extension, distribution code of '2')
* roll the excess to next year with the hope that you can use it as a contribution next year
But when you pass the original due date (or extension date), the first option (withdrawal) is gone. After the original due date (or extension date), you now have these choices:
Subsequent Year
* withdraw the excess as a normal distribution (code '1') - this will not only be taxed as ordinary income, but will also be hit with a 20% penalty.
* roll the excess to next year with the hope that you can use it as a contribution next year (but if you have changed insurance carriers or maybe gone on Medicare, it might never be usable again).
So when TurboTax tells you that you have an excess of $19 for 2022, since you have passed the original due date (April 15, 2023), you could do this:
1. If you will have HDHP coverage next year, make sure that you can include the excess as a personal contribution under your Family contribution limit (i.e., reduce the contributions you would have otherwise made).
2. Keep the 1099-SA with its code of '1', change it so that it is not marked as all for medical expenses, then accept the fact that the distribution amount will be added to Other Income on Schedule 1 (1040) and the 20% penalty will also be added to Schedule 2 (1040).
However, you chose to roll the $19 over to 2024 and then 2025, and I assume that you never had HDHP coverage again, so the $19 was never used up.
When you "withdrew" the $19, you told the HSA custodian that it was something like a withdrawal of excess HSA contributions, so they sent you a 1099-SA with the distribution code of '2'. But this is the correct procedure only if you do the withdrawal in the first year (i.e., before the first due date). Unfortunately, in common English, we use "withdrawal" for any removal of dollars from the account, whereas the IRS uses "withdrawal" in a very specific sense - to remove the excess in a timely manner in the year current with the excess (well, up to the original due date of that tax year).
Don't blame the HSA custodian - they don't know any better.
Now that you are beyond the first year (and its original due date of April 15, 2023), you have to proceed to "Subsequent Year" above. You apparently don't have bullet point 2 available to you (using up the rolled over excess as a personal contribution in a future year). So the only method you have available to you to cut off the continuous carrying over of the excess is to take a distribution from your HSA (distribution code of '1') equal to the amount of the excess, and not marking it as used for medical expenses.
This action will result in the excess being add to Other Income on Schedule 1 (1040), as well as a 20% excise tax ("penalty") added to Schedule 2 (1040). But then, the carryover will be done. Such a distribution cuts off any carryover without you making any special entries.
Thank you so much, Bill. This was not at all apparent, as you said.
So it seems I now have two problems:
Hopefully I can contact the custodian and ask them to reclassify the distribution as a normal distribution?
For anyone following along I contacted the HSA custodian and informed them that the distribution I took did not qualify as an excess-contribution distribution.
They essentially said, “Bummer, man. Better luck next time.”
They say they cannot reclassify the distribution or otherwise produce a new 1099-SA with the amount coded as a normal distribution.
They do have a distribution reversal process, but said that reversal would appear on tax year 2026 instead of tax year 2025. So essentially I can’t “undo” the excess-contribution distribution I made in error.
All the HSA custodian had for me was to “have my tax advisor fix it”. I‘ve talked to two talk preparers now. The last one advised me to have the custodian fix the distribution and produce a new 1099-SA.
No idea how I’m going to fix the distribution made in error.
Thanks for coming back with the update.
Yes, in my experience, HSA custodians are very reluctant to correct things or even fix their own mistakes. They could have accepted your request as a "mistaken distribution" (the 1099-SA with the distribution code of '2') which would have allowed you to ask for a new distribution with a code of '1'. However, the IRS instructions make it clear that the HSA custodian does not have to accept the mistaken distribution request (why such latitude, I don't know), which leaves you stuck.
You have two options:
1. Look on the HSA custodian's website for the form for reporting a mistaken distribution. I can't guarantee that there is one, but if there is, it may provide a different path that may get the request approved. Since the 1099-SA was done in 2026 (yes, the form is 2025, but the HSA custodian probably thought that you were reporting an excess in 2025, so the form makes sense), they shouldn't refuse because the request was too old. Alternatively, you might try calling the support line to see if you get a different customer support rep - there really is no reason for them to refuse a request to treat a distribution like this as a "mistaken distribution" - it's just that it involves more paperwork for them. If being obsequious gets you the results you want, then so much the better.
After you get the mistaken distribution handled, then, as I said above, you can request a "normal" distribution (again, look for the form on the website) with a code of '1'.
2. If you can't get #1 to work, since the amount of the excess is so small, I would just go ahead and ask for the normal distribution of $19, and when the 1099-SA comes in, enter it on your 2026 return. Yes, you will have to pay income tax on the $19 as well as the 20% penalty, but at least the whole excess carryover will be done. Note that you don't have to do anything to tie this 1099-SA to the carryover excess - TurboTax will do that automatically.
Thanks, Bill.
I don’t mind having the excess stay in there for tax year 2025 and then fixing it with a normal distribution in tax year 2026.
I’ve tried several approaches with the bank including talking to multiple agents, talking to a supervisor, submitting a form through their website. All have failed so I don’t think I’m going to get the bank to retract the mistaken distribution.
I’m pretty sure I need to pay a 20% tax on that mistaken distribution, though, right? If so, how do I handle that? Should I just tell TurboTax the 2025 1099-SA was coded as 1 even though it says 2? Is that lying/misrepresentation?
No, sadly, if the HSA custodian hasn't stepped up yet to helping you with this issue, I don't think they're going to.
The problem with changing the distribution code from '2' to '1' on your existing 1099-SA is that any change to a filed form that is copied to the IRS (as the 1099-SA is) invites scrutiny and maybe a letter from the IRS asking why. Also, the records on your HSA that the custodian has won't match what your returns said happened in case of an audit.
However, I have no idea how often such things are audited. So this is a matter of your risk tolerance.
Or you can just ask for a new "normal" distribution. When you enter the 1099-SA with the distribution code of '1', and then tell TurboTax in the 1099-SA subinterview in the HSA interview, then TurboTax will
(1) add the distribution in box 1 to Other Income (Schedule 2 of the 1040, I think), and
(2) calculate the 20% penalty on line 17b of form 8889 and add it to Other Income as well.
(3) cut off any excess that is carried over.
Since this is the way the excess should have been addressed, the auditor shouldn't have any complaint. Then there is only the matter of the first 1099-SA with distribution code of '2', but you can't fix everything - all you can do is your best and hope any auditor understands.
Then there is only the matter of the first 1099-SA with distribution code of '2', but you can't fix everything - all you can do is your best and hope any auditor understands.
Ahhh okay so I would just file my 2025 taxes as-is with the mistaken distribution reported as an excess contribution removal and hope for the best.
I am not sure where you ended up.
I think you should either change the current 1099-SA to '1' or leave that alone and ask or a new "normal" distribution. You have to do one or the other to cut off the carryover.
Thanks so much for all of your help, Bill. I’ve spoken to the HSA custodian, the IRS and two TurboTax experts and none of them have been able to understand the problem and articulate the options as clearly as you have!
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