The routing matrix (18 cells)
| Account variant | Current year (≤ Apr 15) | Prior year (Apr 16 – Oct 15, with timely return or 4868) | Late (after Oct 15) |
|---|---|---|---|
| Roth IRA — dollar-cap excess | §408(d)(4) corrective distribution: withdraw excess + NIA by Apr 15. NIA taxable in contribution year. | §301.9100-2(b) extended correction: same procedure, by Oct 15, IF return was timely-filed (or Form 4868). Mark amended return 'Filed pursuant to section 301.9100-2'. | Two paths: (a) absorb excess in next year's underage; (b) withdraw principal (no NIA reporting). 6% per year on Form 5329 Part IV until cleared. |
| Roth IRA — MAGI phase-out excess | Same §408(d)(4) corrective distribution path. Alternative: §408A(d)(6)(A) recharacterization to Traditional (transfer + NIA — still permitted post-TCJA for contributions). Recharacterization is the elegant fix when MAGI was the trigger and you'd otherwise leave the dollar amount in. | Both paths still available under §301.9100-2(b) extension, IF return was timely-filed. Recharacterization deadline = same Oct 15. | Recharacterization no longer timely. Withdraw principal (no NIA) or absorb in future year's room. 6% per year. |
| Traditional IRA — non-deductible excess | §408(d)(4) corrective distribution: withdraw excess + NIA by Apr 15. Returned amount is basis (not taxable); NIA is taxable in contribution year. | §301.9100-2(b) extended correction. File Form 8606 to track surviving basis if any nondeductible contributions remain. | Withdraw principal + 6% excise on Form 5329 Part III. Form 8606 still tracks any remaining nondeductible basis. |
| Traditional IRA — deducted excess | Withdraw the excess + NIA AND don't deduct it on the original return (§408(d)(4)(B) condition). NIA taxable in contribution year. If you already filed the return claiming the deduction, file Form 1040-X to remove the deduction along with the corrective distribution. | §301.9100-2(b) extended correction with amended return removing the deduction. | Pub 590-A 'Excess Contributions Withdrawn After Due Date' allows tax-free withdrawal IF total contributions ≤ annual cap AND no deduction was taken on the excess; otherwise the withdrawal is fully taxable. 6% excise per year applies regardless. |
| HSA — annual-cap excess | §223(f)(3) corrective distribution: withdraw excess + NIA by Apr 15. NIA includible in 'Other income' for the year RECEIVED (not contribution year). | §301.9100-2(b) extended correction. Year-of-receipt rule for NIA still applies. | 6% excise on Form 5329 Part VII for each year excess remains. Pub 969 lets you absorb excess in next year's underage. |
| HSA — monthly-eligibility / last-month-rule failure | Withdraw the over-contribution (the difference between the full-year cap claimed and the pro-rated cap) plus NIA per §223(f)(3). Failed last-month-rule testing period? The originally-allowed full-year cap retroactively becomes the pro-rated cap, generating retro-excess. | §301.9100-2(b) extended correction. Last-month-rule failures discovered after Apr 15 are common. | 6% excise via Form 5329 Part VII; absorbable in future year's room if you remain HDHP-eligible. |
How to use this matrix
Find your account variant along the left edge, then read across to the column matching today's date relative to the contribution year. The cell content is the procedure name; the statute pin links to the primary source on irs.gov or law.cornell.edu.
Important caveat — the prior-year column is conditional
The middle column applies onlyif you timely-filed the original return for the contribution year (or filed Form 4868 by April 15). Without that, the §301.9100-2(b) automatic extension does not apply, and you fall into the "late" column on April 16 — not October 16.
Roth-conversion gotcha
If your “excess” is actually a botched Roth conversion (not a Roth contribution), the matrix does not help — TCJA eliminated conversion recharacterization for tax years after 2017, so the conversion is locked. Your only recourse is to keep the conversion (and its tax) or to take a regular Roth distribution subject to the ordering rules. See IRC §408A(d)(6)(B)(iii) and the prior-year-vs-current pillar for the contribution/conversion distinction.
Also relevant
- When to file — the underlying §301.9100-2(b) extension mechanic, in detail.
- Prior-year vs current-year excess — which year's 1099-R you receive, and the §408A(d)(6) recharacterization split.
- Form 5329 walkthrough — what to file when you're past timely.
- Run the NIA calculator — the earnings number you'll need on the corrective form.
- Removal decision tree — interactive routing through the same matrix.
Informational, not tax advice. Consult a CPA or Enrolled Agent before acting on a corrective distribution.