The Once-in-a-Lifetime IRA Transfer to an HSA

The Tax Code is riddled with esoteric deductions even many tax professionals are unaware of. So rare is the topic of today’s discussion that I never once in my career had a client use what I am about to point out.

Before you get too excited, know that just because you can do something doesn’t mean you should. Only under a unique set of circumstances would using this tax strategy be beneficial so read carefully. You only get one shot at this strategy because it is only allowed once in your lifetime. 

It’s called a Qualified HSA Funding Distribution (QHFD). In short, a QHFD allows you to fund your HSA with pre-tax monies in a traditional or Roth IRA or inactive SEPs and SIMPLEs. 

Let’s dig into the details before we discuss when it is appropriate to use your once-in-a-lifetime election and when it isn’t. 

 

Characteristics

1. You must still qualify for an HSA contribution when using an QHFD. This means you must have an HSA qualified health insurance plan with applicable high deductibles.
2. You must remain eligible for an HSA for 12 months or longer after making a QHFD. If you are not HSA compliant for at least 12 months after the QHFD you must include the distribution in  your income along with any penalty if under age 59 1/2.
3. You must use a trustee-to-trustee transfer. You are not allowed to take the money out and then put it in the HSA. (Well, actually, you can, but the IRA distribution would be included in income — along with penalties if under age 59 1/2. But you would get the HSA deduction, offsetting the IRA distribution included in income.)
4. A QHFD does not increase the amount you can put in an HSA for that year. Contribution limits still apply.
5. You also do not get an HSA deduction for funds transferred from an IRA; the money is already pre-tax.
6. An inherited IRA can be used for a QHFD.
7. The QHFD lowers your RMD by the amount transferred for the year of the transfer.
8. There is no 10% early distribution penalty with a QHFD as long as you follow the 12 month rule and qualify for an HSA.
9. This strategy can only be used once-in-a-lifetime per taxpayer.

 

Why Would Anyone Do This?

When you think about this for awhile it might seem a counter-productive tax move. (We will discuss instances where the QHFD is advantageous later.) You are not allowed a larger contribution to the HSA with this strategy and you get no additional deduction either.

Roth IRAs are a non-starter. rIRAs are already growing tax-free so moving money from a rIRA to an HSA provides no additional advantage with the added restrictions, such as the 12 month requirement listed above and a QHFD is limited to pre-tax dollars.

SEPs and SIMPLEs must be inactive to employ this strategy. This means contributions are no longer added to the account. The IRS is silent on how long an account must go without contributions to be considered inactive or if the SEP or SIMPLE can become active in the future.

There are a number of situations where the QHFD is superior to just funding the HSA and getting an additional deduction:

1. You don’t have the money to fully fund your HSA this year. Since you would not fund your HSA anyway you end up with additional cash in the HSA that now grows tax-free instead of tax-deferred (I assume throughout this post that you use a QHFD from a tIRA to an HSA.) 
2. If your tIRA is large and significant RMDs loom, any tax-free distribution from the tIRA is advantageous. It also lowers the RMD by the amount of the QHFD for that year.
3. This strategy is better than taking an IRA distribution and paying the penalty (if under age 59 1/2) and then contributing to the HSA.
4. You want (or your facts and circumstances dictate) to turn tax-deferred growth into tax-free growth. Remember, a tIRA grows without tax until withdrawn; an HSA grows tax-deferred and if used for qualified medical expenses and/or Medicare premiums the money comes out tax-free at any age.
5. High medical bills make it difficult to fund the HSA and access to HSA funds are needed for uncovered medical expenses.

There are other reasons to use a QHFD, based on facts and circumstances and personal preference. Personally, I think people with large IRAs might want to employ this tax strategy and these that lower their future RMDs. 

 

Gaming the System

For 2019 you can contribute $3,500 for individual health plans and $7,000 for family plans into an HSA. (Those 55 and older can add another $1,000 to their HSA as part of the catch-up provision.)

In The Wealthy Accountant private group on Facebook a member asked about this tax strategy. Since the issue never arose in my office I wanted to dig a bit before answering and then couldn’t find the original post on Facebook (fingers crossed the person who asked finds this post.)

His question was about gaming the QHFD to double the tax benefit by transferring two years of contributions by making the contribution in the cross-over months (up to April 15th of the following year without consideration for extensions). He wanted to know if he could make, say, a $14,000 family plan contribution: half for last year and half for this year.

He did his research and found the IRS and all other sources silent on the issue. I found the same thing.

However, after I thought about it for awhile I realized this would NOT work. The once-in-a-lifetime QHFD would have to go on two tax returns if you doubled the transfer during the cross-over months which would make the second election disqualified. Sorry. But I like the way you think.

 

Round Up

The concept is rather simple. The benefits are fairly small, but worth it if your situation dictates. Those facing large RMDs and those seeking to turn a small portion of their tax-deferred tIRA into tax-free growth in an HSA will find the most value.

Now I need to make a confession. When I first saw the question in the private Facebook group I thought the person posting was smoking something. I never heard of such a tax strategy (or it went in this ear and out the other.) I had to look it up to believe.

If you plan on using this strategy don’t get mad at your tax professional if they never heard of this. Just tell them to go to their software’s Special Situations tab on the 1099-R screen. All they need to do is add one simple number (the amount transferred to the HSA up to the contribution limit).

If you run across a tax strategy you never heard of before be sure to leave a comment. If possible I will leave a short answer. And, as in this situation, I may flesh it out a bit more in a post. 

Many of these strategies provide only a small tax benefit. Added together with several other small tax strategies can accumulate to serious tax savings. 

Hope this one works for you or at least gets you thinking about another tax saving strategy that improves your financial situation.

 

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