The IRS recently issued Notice 2020-35 which, among other items, extends the filing deadline for 2019 Form 5498, Form 5498-ESA and Form 5498-SA to August 31, 2020 due to ongoing impact from the COVID-19 pandemic. These forms are used by custodians and trustees to report contributions made by beneficiaries and participants to individual retirement accounts (5498), educational savings accounts (5498-ESA), and health savings accounts and medical savings accounts (5498-SA).

In an ordinary year, the filing deadline for these forms is May 31 for contributions made with respect to the prior tax year. Earlier this year, the IRS had extended the deadline for 2019 Form 5498 filings to July 15, 2020. The concern raised by practitioners, however, was that even with this deadline extension, custodians and trustees would not be able to capture all contributions made by participants since the deadline for contributions (e.g., IRA contributions for 2019) had also been extended to July 15.

The extended August 31 filing deadline allows financial institutions time to process contributions made by July 15 for reporting purposes. However, the contribution and extended Form 5498 filing changes will require that such institutions review and closely monitor their 5498 information gathering and reporting processes for this reporting year.