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Reviewed by: William McLee
Reviewed date:
February 19, 2026

Instructions for Form 5329 - 2021 Tax Year Checklist

Form 5329 for the 2021 tax year reports additional taxes tied to tax-advantaged accounts,

including early distributions, excess contributions, and missed required minimum distributions under federal tax laws. This checklist aligns with the IRS Form 5329 instructions, Schedule 2 of

Form 1040, and Internal Revenue Service guidance for qualified retirement plans and other tax-favored accounts.

Form 5329 applies to individual retirement arrangements, employer retirement plans, education savings accounts, and similar arrangements subject to excise tax rules under the Tax Code. The checklist emphasizes accurate identification of taxable amounts, proper exception claims, and correct transfer of totals to tax returns prepared for the applicable tax year.

Before the Checklist: Information to Gather

Before completing Form 5329, collect Form 1099-R reporting pension and annuity income, along with IRA custodian statements for each retirement account involved during the tax year.

Ensure Social Security Number details match Form 1040, and retain records for Roth IRA basis, traditional IRAs, inherited IRA activity, and distributions from individual retirement arrangements.

If education savings accounts apply, gather records for a Coverdell ESA, a 529 plan, or an

ABLE account that show the taxable and nontaxable portions and qualified expenses. For excess contributions or minimum required distributions, retain documentation supporting IRA contributions, year-end balances, Archer MSA or Health Savings Account records, and any penalty waiver request.

Ten-Step Checklist for Form 5329 (2021)

  1. Step 1: Confirm whether Form 5329 must be filed

    Form 5329 is required when additional taxes apply to early distributions, excess contributions, or missed required minimum distributions that are not fully reported through Form 1040 schedules. Each spouse must complete a separate Form 5329 when both have filing requirements, even if tax returns are filed jointly for the same tax year.

  2. Step 2: Identify early distributions subject to additional taxes

    Early distributions generally occur before age 59½ and apply across qualified retirement accounts, employer plans, and individual retirement arrangements, unless a penalty exception applies. Timing depends on the actual distribution date rather than year-end age, requiring careful review of Form 1099-R distribution codes and payment records.

  3. Step 3: Determine the taxable amount for Part I

    Part I uses the portion of early distributions included in federal taxable income rather than total distributions reported by retirement plans or IRA custodians. For Roth IRA distributions or nondeductible IRAs, taxable portions often require Form 8606 calculations to determine the correct amount subject to additional taxes.

  4. Step 4: Apply penalty exceptions correctly

    Penalty exceptions must be claimed using numbered exception codes listed in the 2021 instructions rather than outdated letter-based systems. Common exceptions include death benefits, disability, unemployment compensation coverage, higher-education expenses, and a first-time homebuyer distribution when applicable requirements are met.

  5. Step 5: Compute additional taxes on early distributions

    Compute the 10% additional tax on amounts remaining after applying exceptions, and apply a higher rate to certain SIMPLE IRA distributions if required. This calculation uses a fixed percentage rather than marginal brackets, so documentation must clearly support taxable amounts and any penalty exception applied.

  6. Step 6: Review coronavirus-related distributions carefully

    Coronavirus-related distributions relate to 2020 activity but may affect 2021 filings through income inclusion or recontribution treatment. Qualified disaster distributions are not subject to the 10% penalty, and taxpayers should use disaster-specific forms rather than Form 5329 for those adjustments.

  7. Step 7: Identify Excess contributions across accounts

    Excess contributions occur when IRA contributions or deposits exceed the contribution limits and remain uncorrected at year-end. Affected accounts may include traditional IRAs, Roth IRA accounts, Coverdell Education Savings Account arrangements, Archer medical savings accounts, and an ABLE account.

  8. Step 8: Use the correct parts for excess contribution taxes

    Traditional IRA excess contributions are reported in Part III, while Roth IRA excess contributions are reported in Part IV of the IRS Form 5329 instructions. Parts V through VIII apply to education savings accounts and ABLE account excess issues, while Part II is not appropriate for IRA excise tax reporting.

  9. Step 9: Confirm Required Minimum Distribution compliance

    Determine whether a required minimum distribution applied for 2021 using life expectancy rules, employer plan status, and year-end account balances. Missed mandatory distributions are reported in Part IX and generally trigger a fifty percent excise tax unless a valid penalty waiver request applies.

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  10. Step 10: Transfer totals and retain records

    Transfer all computed additional taxes to Schedule 2 of Form 1040 using the correct line references for the 2021 tax year. Retain Form 1099-R, Publication 590-A references,

    Publication 590-B guidance, and supporting records in case of IRS review or state tax inquiries.

    Closing Notes and Recordkeeping

    Maintain organized records for retirement plans, tax-advantaged accounts, and education savings accounts to support accurate reporting and penalty exception claims. Strong documentation assists with Internal Revenue Service questions, IRS website transcript reviews, and reconciliation of federal taxable income reported on tax returns.

    Complex situations involving employer plans, life annuities, or multiple qualified retirement plans may warrant review by a knowledgeable tax professional. Professional review helps ensure

    Form 5329 aligns with federal tax laws, tax regulations, and evolving guidance affecting tax-favored retirement savings plans.

    If you’re missing tax documents or want to ensure the numbers you enter match IRS records, we can help.

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