Instructions for Form 5329 - 2015 Tax Year Checklist
This checklist provides a corrected, 2015-specific framework for determining when and how
Form 5329 applies to additional taxes tied to tax-favored account activity. It addresses early
distributions, excess contributions, distributions from education accounts, and minimum required distributions under federal tax laws.
The guidance aligns with the 2015 IRS Form 5329 structure and Form 1040 reporting conventions, using rules applicable to that tax year rather than later procedural changes. It is designed for accurate compliance, not penalty minimization strategies.
Required Information and Source Documents
Preparation should start by gathering Form 1099-R for distributions from pensions and any related retirement plan activity, then matching taxpayer identifiers to the Social Security Number shown on Form 1040 records. IRA custodians’ statements should be reconciled for traditional
IRAs, Roth IRA activity, and any Individual Retirement Arrangements that involve rollovers, corrections, or recharacterizations.
Education savings accounts require documentation showing the taxable versus nontaxable portions for a Coverdell ESA, a 529 plan, or an ABLE account, plus qualified expense documentation. If excess contributions or required minimum distributions apply, records should include IRA contributions, correction transactions, year-end balances used for the 2015 RMD, and support for the penalty waiver request.
Ten-Step Checklist (2015)
Step 1: Confirm whether Form 5329 applies for the 2015 tax year
Form 5329 is required when additional taxes apply to early distributions, excess contributions, missed minimum distributions, or taxable education account distributions not fully resolved through information return codes. If all early distributions are fully taxable, correctly coded on
Form 1099-R, and no exceptions apply, the additional tax may instead be reported directly on
Form 1040 or Form 1040NR.
Step 2: Identify the relevant Form 5329 parts for each issue
Form 5329 is divided by topic, with separate parts covering early distributions, education savings accounts, excess contributions, and required minimum distributions. Multiple parts may be completed in the same tax year when retirement plans, Coverdell ESAs, ABLE accounts, or
Individual Retirement Arrangements trigger more than one category of additional taxes.
Step 3: Determine whether a distribution is considered early
An early distribution occurs when funds are distributed from a qualified retirement account before the account holder reaches age 59½, based on the actual distribution date. Age is tested at the time of distribution, not at year-end, so birth date and payment date should be verified using Form 1099-R and IRA custodian statements.
Step 4: Identify the taxable amount subject to the additional tax
The starting point for computing additional taxes is the portion of distributions included in income, typically shown as taxable pension and annuity income on Form 1099-R. Amounts properly rolled over or excluded from income are not subject to the additional tax, while taxable earnings from education savings accounts can trigger a separate computation framework.
Step 5: Evaluate whether an exception to the additional tax applies
Exceptions should be claimed when distribution codes do not fully reflect eligibility, and Form
5329 provides the method for accurately reporting those exceptions on tax returns. Eligibility depends on account type and facts, including death, disability, medical expenses, first-time homebuyer rules for IRAs, separation from service rules for certain employer plans, or qualified reservist distributions.
Step 6: Apply the correct medical expense threshold for 2015
The medical expense exception applies only to unreimbursed expenses exceeding 10% of adjusted gross income, or 7.5% for qualifying older taxpayers under the 2015 special rule. Using the wrong threshold can overstate the amount of the exception, so the applicable adjusted gross income percentage should be confirmed before reducing early distribution additional taxes.
Step 7: Handle substantially equal periodic payments under SEPP rules
Substantially equal periodic payments must follow approved calculation methods and continue for five years or until age fifty-nine and one-half, whichever period is longer. Improper modification can retroactively trigger an IRS penalty, so SEPP calculations and payment records should be retained even when no attachments are required for filing.
Step 8: Address education savings accounts and ABLE accounts correctly
Part II applies when taxable distributions from a Coverdell Education Savings Account, a 529 plan, or an ABLE account are included in income, unless an exception applies. The taxable portion depends on earnings allocation and qualified expense matching, so documentation should support how qualified expenses reduce taxable earnings for the 2015 tax year.
Step 9: Compute excise tax on excess contributions and RMD shortfalls
Excess contributions to traditional IRAs, Roth IRA accounts, and other covered arrangements can trigger a six percent excise tax each year the excess remains uncorrected. Failure to take
the minimum required distributions triggers a 50% excise tax on the shortfall, unless reasonable explanations of the error support a penalty waiver request.
- Full IRS transcript retrieval (Wage & Income + Account)
- Professional tax form review
- Preparation & filing support
- Tax relief options if you owe the IRS
Step 10: Report totals correctly and maintain supporting records
Additional taxes computed on Form 5329 are carried to the appropriate line of the 2015 Form
1040 or Form 1040NR and filed with the return when required by the instructions. Forms
1099-R, education account records, IRA contribution documentation, Publication 590-A and
Publication 590-B references, and exception support should be retained for Internal Revenue
Service review and future tax return consistency.
Closing Notes
Form 5329 supports consistent reporting of additional taxes affecting qualified retirement plans and other tax-favored accounts under the 2015 tax regulations. When multiple income sources, custodians, or exception claims apply, a tax professional's review can help confirm accurate reporting while reducing avoidable IRS penalty exposure.
If you’re missing tax documents or want to ensure the numbers you enter match IRS records, we can help.

