Your eligibility to claim a deduction for your Traditional IRA contribution on your federal tax return depends on whether you are an
active participant of an employer-sponsored plan in the year to which your deduction applies. If neither you nor your spouse is an active participant, you may deduct your full contribution for the year, to which a limit applies. If, however, you are an active participant, your tax-filing status and modified
adjusted gross income (MAGI) determine your eligibility to deduct your IRA contribution. Here we take a look at how to determine your active-participant status, which can be tricky as the rules vary for each type of employer-sponsored retirement plan. (see
Traditional IRAs: Contributions.)
TUTORIAL: Traditional IRAs
W-2 Designation If you are an active participant, your employer should indicate as such on your
Form W-2 by checking the "retirement" box. However, administrative errors can happen, so this box is sometimes not checked even when it should be. It's helpful for you to understand the rules, so that you don't have to rely on your employer's reports to determine whether you are considered an active participant for a tax year.
Determining Active Status The rules regarding active-participant status are different for different types of employer retirement plans. (For more, read
10 Most Overlooked Tax Deductions.)
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Defined-Benefit Plan
If you are eligible to participate in a
defined-benefit plan for the tax year, you are considered an active participant for that year. This is so even if you decline to participate in the plan, fail to make mandatory contributions to the plan or fail to perform the minimum service required to accrue a benefit under the plan for the year.
Money-Purchase Pension and Target-Benefit Plan For
money-purchase pension and
target-benefit plans, you are considered an active participant for the year to which your contributions to these plans apply. This is so, regardless of when your contribution is actually deposited to your account.
For example, say your employer sponsors a money-purchase pension plan, and is required to contribute 10% of eligible compensation to the plan each year. Your employer has until its tax-filing deadline, including extensions, to deposit a particular year's contributions. So, if a 2011 contribution was made in 2012, you are considered an active participant for the 2011 tax year, the year to which the contribution applies.
Profit-Sharing Plans and SEP IRAs With plans to which contributions are discretionary, such as
profit-sharing plans and
SEP IRAs, employees are considered active for the year in which the contributions are actually deposited to the employees' accounts - even if the contributions apply to the previous year. The reason for this rule is that it is usually impossible for employers to guarantee contributions to these plans for any particular year.
To demonstrate, let's say your employer sponsors a profit-sharing plan, to which it contributes 10% of eligible compensation for the 2011 tax year. But the contributions are deposited in 2012. Employees are considered active participants for 2012, the year in which the contributions are actually deposited to their accounts.
401(k) and 403(b) Plans If you make
salary-deferral contributions to a
401(k) or
403(b) plan, you are considered an active participant for the year to which your salary-deferral contributions apply. If you are eligible to make salary-deferral contributions but elect not to, you are
not considered an active participant for that year.
Voluntary or Mandatory Contributions
You are considered an active participant for any year you make voluntary or mandatory contributions to an eligible employer-sponsored retirement plan. (A list of the eligible plans is
here.)
Vesting Status Does Not Affect Active-Participant Status Depending on the plan provisions, you may not be immediately vested in the year's contributions you receive from your employer. But your
vesting status does not alter whether you are an active participant. This means that even if you leave that employer at a later date and you forfeit that non-vested contribution, you are still considered an active participant for the applicable year. (Read
10 Tax Benefits For The Self-Employed for more information.)
Example
ABC Company contributes of 10% of its employees' compensation to its money-purchase pension plan for the 2011 tax year. Under the provisions of the ABC money-purchase pension plan, employees' contributions are 100% vested after working three years - no vesting occurs before then. Jane leaves ABC Company for a new firm after two years of employment.
Because Jane is leaving before she accrued any vested balance, she must forfeit the contributions that were made to her money-purchase-pension account at ABC Company. However, Jane is still considered an active participant for the 2011 tax year, because a required contribution was made to her money-purchase pension account.
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Conclusion If you and/or your spouse are active participants for a given year, you may need to perform a calculation to determine whether you are able to deduct your IRA contributions for that year. If you are not able to deduct the full amount, you may be able to deduct a portion, depending on your MAGI. This formula is explained in IRS
Publication 590, available at
http://www.irs.gov/. Ultimately, you may want to consult with your tax professional for assistance with determining whether your IRA contribution is deductible.
by
Denise Appleby is founder and owner of
Appleby Retirement Consulting,which provides technical consultation, content, coaching, writing, editing and training services on related topics.
With more than 14 years of experience in the IRA and defined-contribution plans fields, Appleby has held several senior retirement-plan related positions with Pershing LLC, which included vice president of plans products and services, retirement plans manager, trainer, training manager, compliance consultant, technical help desk manager and writer.