Write “Puerto Rico Earthquakes (DR‑4473‑PR)” at the top of page 1 when you file 2024 Form 8915‑D with your 2024 Form 1040.
Key Takeaways
- Form 8915‑D (2024) is for repayments you made in 2024 of qualified disaster distributions tied to the 2019 Puerto Rico Earthquakes, DR‑4473‑PR. It files with your 2024 Form 1040, 1040‑SR, or 1040‑NR.
- Only distributions taken in 2021 for DR‑4473‑PR can still be repaid in 2024, because the repayment period ends 3 years and 1 day after the distribution date.
- Use Part I for plans other than IRAs, use Part II for IRAs, and spouses file separate Forms 8915‑D if both have repayments.
- Repayments are treated as trustee to trustee transfers, they are not rollovers, so the IRA one‑per‑year rollover limit does not apply.
- If your 2024 repayment reduces income that you already reported in 2021, 2022, or 2023, amend those returns with Form 1040‑X and carry the repayment back to the correct line for that year.
What Form 8915‑D (2024) Actually Covers
Form 8915‑D is narrowly focused, on purpose. Use the 2024 version only to report repayments you made in 2024 for qualified disaster distributions that were tied to the 2019 Puerto Rico Earthquakes, DR‑4473‑PR. If your situation involves a different 2021 or later disaster, that goes on Form 8915‑F instead.
What counts as a “qualified disaster distribution” here, and why does that matter? Qualified disaster distributions for DR‑4473‑PR can be included in income ratably over three years, or, if you elected, all in the year you took the distribution. Either way, a timely repayment within the allowed period reduces income. These distributions are also not subject to the 10% additional tax, or the 25% additional tax for certain SIMPLE IRA early distributions, up to the qualified disaster limit.
Who should file 2024 Form 8915‑D
File if all of the following are true:
- You took a qualified disaster distribution for DR‑4473‑PR.
- The distribution date was in 2021.
- You made a repayment in 2024 within the three year window measured from the day after your original distribution date.
- You need that repayment reflected on your 2024 return, and possibly carried back to reduce income in 2021, 2022, or 2023.
On joint returns, each spouse files their own Form 8915‑D if both have repayments. If you are not otherwise filing a 2024 income tax return, you still send the signed Form 8915‑D to the same place you would file Form 1040.
The Three Year Repayment Window, How It Works
Your clock starts the day after the distribution date, not at year end. The window ends exactly 3 years and 1 day after the date you received the money. If you took the distribution on May 25, 2021, the latest day to repay for Form 8915‑D treatment was May 25, 2024. Anything paid after that cannot be treated as a repayment for this relief.
Repayments that meet the timing rule are treated as trustee to trustee transfers, excluded from income, and do not count toward the one‑rollover‑per‑year limitation for IRAs. Keep confirmations, dates, and statements that tie each repayment to its original distribution.
A quick real‑world example
Say you withdrew 90,000 from a traditional IRA on April 30, 2021 due to DR‑4473‑PR and chose the three year spread, 30,000 in income for 2021, 2022, and 2023. On April 20, 2024, you repaid 60,000. Because the repayment happened before May 1, 2024, it is within your three year window, so you can carry 30,000 to 2023 and 30,000 to 2022. Then amend those years so the repayment reduces income in each year. This mirrors how the IRS instructs taxpayers to allocate excess repayments across prior years.
Income Inclusion Choices, Three Year Spread or Full Year
For qualified 2019 disaster distributions, you had two choices when you first reported the distribution, spread the income equally over three years, or include it all in the year you received it. You must apply the same method to all your qualified distributions taken in that year. If you later make a timely repayment, it reduces the income under your original choice, which may require you to amend earlier years.
Three year ratable inclusion
- Default method, equal amounts over the distribution year and the next two years.
- Timely repayments made by your return due date, including extensions, and within the three year window reduce the amount you include for that year.
- If you already filed and then repaid in 2024, you generally amend the affected years to apply the repayment.
Elect full year taxation
- You could elect to include the entire distribution in income in the year you took it.
- If you later repay within the allowed window, you can carry the repayment back to that inclusion year and amend it.
Penalty Relief, What Is Waived and When
Qualified disaster distributions for DR‑4473‑PR are not subject to the 10% early distribution additional tax, or the 25% additional tax for certain SIMPLE IRA early distributions. The disaster distribution limit for these provisions is up to 100,000 per affected taxpayer for eligible disasters, and repayments made within the allowed timeframe are treated as trustee to trustee transfers. Always confirm your total qualified disaster distribution amount for the event before you rely on penalty relief.
What does not qualify
Certain withdrawals cannot be repaid or treated under these rules, including distributions received as a non‑spouse beneficiary, required minimum distributions, and certain series of substantially equal periodic payments. If a distribution falls into one of these categories, normal early distribution rules apply.
Plans and Accounts You Can Repay To
You can repay any portion of the qualified distribution to an eligible retirement plan that accepts rollovers, subject to plan rules, and you cannot repay more than the original distribution. This includes employer plans like qualified pension or profit‑sharing plans, 401(k), 403(b) annuities, and governmental 457(b) plans, as well as IRAs, traditional, SEP, SIMPLE, and Roth. For IRAs, repayments are treated as trustee to trustee, not rollovers, so the one‑per‑year rollover cap does not apply.
Practical tip from the review desk
When you send a repayment, label it clearly with the disaster name and the original distribution date so your custodian codes it correctly. Save confirmations and account statements with your tax file. It is the paper trail that proves eligibility if the IRS asks.
Common Mistakes That Create Rework
- Missing the 3 years and 1 day deadline by a few days, which disqualifies repayment treatment.
- Filing a single 8915‑D for both spouses on a joint return, each spouse needs a separate form.
- Forgetting the required annotation at the top of page 1, “Puerto Rico Earthquakes (DR‑4473‑PR).”
- Carrying repayments back to the wrong lines for the prior year forms.
- Treating an IRA repayment as a rollover, then running into the one‑rollover‑per‑year rule, which does not apply here.
If your repayment is timely, it is excluded from income and treated like a trustee to trustee transfer, not a rollover. Keep every document that proves timing and amount.
How To Report 2024 Repayments On Form 8915‑D
- Put plan repayments, not IRAs, in Part I.
- Put IRA repayments in Part II.
- Include only repayments made in 2024 that are still within the three year window for that specific 2021 distribution.
- If you already carried part of a repayment back to a prior year, report that on line 2b for plans or line 7b for IRAs.
Eligibility and timing checklist
- Confirm the original distribution was for DR‑4473‑PR and occurred in 2021.
- Confirm your 2024 repayment date is within three years from the day after your distribution date.
- Write “Puerto Rico Earthquakes (DR‑4473‑PR)” at the top of page 1.
- Decide whether you need to amend 2021, 2022, and or 2023.
Which lines to use for carrybacks
When your 2024 repayment exceeds what would otherwise be on your 2024 Form 8915‑D, you carry the excess back to the correct prior year line. Use the table below.
Carryback line map for DR‑4473‑PR repayments
| Year affected | Non‑IRA plan, include on | IRA, include on |
| 2021 | Line 18 | Line 34 |
| 2022 | Line 7 | Line 16 |
| 2023 | Line 5 | Line 12 |
On the dotted line next to each entry, write “$_____ carryback from 2024 Form 8915‑D” or “$_____ excess repayment from 2024 Form 8915‑D,” as appropriate.
Amending Prior Year Returns
If your repayment reduces income that you already reported, file Form 1040‑X for each affected year and attach that year’s Form 8915‑D showing the carryback. The IRS provides a two step process in the instructions for how to allocate and document carrybacks, including split allocations across multiple years when needed. File within Form 1040‑X deadlines.
Case study, fast review
You took a 75,000 plan distribution on June 1, 2021 for DR‑4473‑PR, elected the three year spread, then repaid 50,000 on May 1, 2024. Your 2024 Form 8915‑D shows the 2024 repayment, then you carry 25,000 back to 2023 and 25,000 back to 2022 using the specific lines in the table above, with the dotted line annotation required by the IRS. This aligns with how the IRS examples apply excess repayments across years.
Exceptions and Ineligible Distributions
You cannot repay, or claim repayment treatment for, distributions received as a beneficiary other than a surviving spouse, required minimum distributions, or non‑IRA series of substantially equal periodic payments that meet the 10 year or life expectancy tests. If your distribution falls into one of these categories, do not report it as a qualified disaster repayment.
Documentation to keep
- Distribution statement that shows the date and amount.
- Proof you were affected by the DR‑4473‑PR disaster, keep what your plan or custodian relied on.
- Repayment confirmation with date, account, and amount.
- Copies of all Forms 8915‑D filed for 2021, 2022, 2023, and 2024, plus any 1040‑X filings.
Small step that saves hours, keep a one page cover sheet listing each distribution date, amount, repayment date, destination account, and which line you used for carrybacks.
Filing Details And Special Annotations
- Attach 2024 Form 8915‑D to your 2024 Form 1040, 1040‑SR, or 1040‑NR.
- If you are not otherwise filing a 1040, sign and mail Form 8915‑D to the place you would file your 1040.
- For foreign addresses, put only the city on the city line, then complete the additional fields below it without abbreviating the country.
- On joint returns, list only the spouse whose data appears on that Form 8915‑D.
- Remember the top of page 1 annotation, “Puerto Rico Earthquakes (DR‑4473‑PR).”
FAQs
Do I have to repay a qualified disaster distribution?
No. Repayment is optional. If you repay within the allowed three year period, that repayment is treated as a trustee to trustee transfer and can reduce income for the distribution year or years. If you do not repay, you keep the income you originally reported under your chosen method.
I used the three year spread. How do I apply a 2024 repayment?
Report the repayment on 2024 Form 8915‑D, then carry the excess back to 2023 and 2022, and if needed 2021, using the specific lines in the table above. Amend those returns with Form 1040‑X so the repayment reduces income in those years.
What if I missed my three year deadline by a few days?
Amounts paid more than 3 years and 1 day after you received the distribution cannot be treated as repayments under these rules. If you missed the deadline, the payment will not qualify for Form 8915‑D treatment.
Does the IRA one‑rollover‑per‑year limit apply to repayments?
No. A repayment to an IRA under these rules is not considered a rollover, so the one‑per‑year limit does not apply. The repayment is treated as a trustee to trustee transfer.
What is the per‑taxpayer cap for qualified disaster distributions?
For qualified disaster relief provisions, the cap is up to 100,000 per affected taxpayer. Confirm your event, timing, and amounts against the IRS rules that applied to your disaster year.
Where Accountably Fits, Only If You Need Help
If your team is buried in compliance, you can hand off the mechanics without losing control. Our U.S. led offshore delivery teams document disaster distributions, standardize 8915‑D workpapers, and process carrybacks with the required dotted line annotations so your reviewers spend minutes, not hours. We work inside the same tax suites you already use, and we follow your SOPs for review notes, naming, and deadlines. Use us when you need capacity that stays disciplined, not just more resumes.
Final Checklist
- Distribution occurred in 2021 for DR‑4473‑PR.
- Repayment made in 2024 within 3 years and 1 day of the distribution date.
- 2024 Form 8915‑D attached to 2024 Form 1040, with the top line annotation.
- Carrybacks entered on the correct lines for 2021, 2022, 2023, and 1040‑X filed as needed.
- Proof of timing and amounts saved with your records.
Disclaimer
This article is for general information. It is based on the IRS Instructions for Form 8915‑D (2024) as available on November 11, 2025, and on official IRS disaster distribution guidance. Always verify facts against the current IRS instructions for your situation, and consult a qualified tax professional before filing.