What Is Form 8852 and Who Is Required to File It?
Understand Form 8852, the IRS informational return used by trustees to report annual activity and value for Archer and Medicare Advantage MSA accounts.
For Archer MSAs and Medicare Advantage MSAs, the financial institution acting as the trustee or custodian is responsible for filing informational returns with the Internal Revenue Service (IRS). Individual taxpayers do not complete these forms. Instead, trustees report annual account activity using two separate forms: Form 5498-SA to report contributions and Form 1099-SA to report distributions. This provides account holders with the information needed to file their personal income tax returns.
Who Must File
The obligation to file these forms rests with the trustee or custodian of an Archer Medical Savings Account (MSA) or a Medicare Advantage MSA. These trustees are typically banks, insurance companies, or other financial institutions approved by the IRS to manage these accounts. A trustee’s filing requirement is triggered when certain events occur during the calendar year.
If any contributions are made to an account, the trustee must file Form 5498-SA. If any distributions are made, the trustee must file Form 1099-SA. The death of the account holder during the tax year also necessitates filing.
Information Required on the Forms
Both forms require the trustee’s identifying information, which includes the institution’s legal name, mailing address, and taxpayer identification number (TIN). They also require the account holder’s full name, mailing address, and Social Security Number (SSN).
Form 5498-SA, HSA, Archer MSA, or Medicare Advantage MSA Information, reports the total contributions made to the account during the year. The trustee must also report the Fair Market Value (FMV) of the account as of the last day of the calendar year. Form 1099-SA, Distributions From an HSA, Archer MSA, or Medicare Advantage MSA, reports the total gross distributions paid out from the account.
How and When to File
The submission deadlines to the IRS and the account holder differ for each form. A copy of Form 1099-SA must be furnished to the account holder by January 31 of the year following the distribution. The deadlines for Form 5498-SA are later in the year.
Trustees are required to file the form with the IRS and furnish a copy to the account holder by early June for the preceding tax year. The completed paper forms are sent to a designated IRS service center. Failure to comply with the filing requirements can result in financial penalties for the trustee for each form that is not filed by the due date or is filed with missing or incorrect information.