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Assume the following scenario for married couple living in the US:

  • Both spouses have coverage under the High Deductible Health Plan (HDHP) of spouse A
  • Spouse B does not have coverage under any other HP
  • A and B reside in different states
  • A's Employer contributes $500 to HSA tied to the HDHP
  • B still has an HSA from a previous year when both spouses had individual coverage under their respective HDHPs
  • A and B file taxes as Married Filing Separately (MFS)

1) Is there a way for A and B to make contributions to any of the two existing HSAs, such that B can claim the full 2019 deduction of $7000 and A claims $0 deduction? If yes, what are the possible contribution allocations that would result in this possibility?

2) Same question, but now such that A claims full deduction and B claims nothing.

I read through the IRS publication on HSA but I was not able to conclusively answer my questions.

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Because Spouse A and Spouse B are both covered under a family plan, they are each considered eligible individuals for HSA contributions, which means that they are both able to contribute to their HSAs. The 2019 family contribution limit of $7,000 must be split between the two of them. This $7,000 limit can be split between the two spouses in any way that they choose.

However, if Spouse A's employer contributes $500 to A's HSA, that means that the couple can only contribute $6,500 of their own money to the HSAs. As a result, neither spouse will be able to claim a full $7,000 HSA deduction, because the employer has contributed $500 to an HSA on your behalf with tax-free money.

The couple can split that $6,500 limit up between the two HSA accounts any way they want. They may contribute the full $6,500 to A's HSA (with A taking the $6,500 deduction), or they could send $6,500 to B's HSA (with B taking the $6,500 deduction), or they could send some to each, with each spouse taking a partial deduction on his or her tax return.

The contribution limits and deductions for the couple are the same whether they file jointly or separately, but when they file separately they need to coordinate and make sure that they don’t go over the combined limit on the two returns.

From IRS Publication 969, Contributions to an HSA:

Rules for married people. If either spouse has family HDHP coverage, both spouses are treated as having family HDHP coverage. If each spouse has family coverage under a separate plan, the contribution limit for 2017 is $6,750. You must reduce the limit on contributions, before taking into account any additional contributions, by the amount contributed to both spouses' Archer MSAs. After that reduction, the contribution limit is split equally between the spouses unless you agree on a different division.

The rules for married people apply only if both spouses are eligible individuals....

Employer contributions. You must reduce the amount you, or any other person, can contribute to your HSA by the amount of any contributions made by your employer that are excludable from your income. This includes amounts contributed to your account by your employer through a cafeteria plan.

One more thing: I’m not sure why you are asking about 2019 limits, but to be clear, for the year that we are in right now, 2018, the family HSA contribution limit is $6,900. This is the limit for contributions you can make this year and is the limit you will use when submitting your next tax return early next year. The $7,000 limit is for contributions made in 2019, and is the limit you will use on your 2019 tax return, which is submitted in early 2020.

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    I don't think you mentioned any differences for filing MFJ vs MFS. If there aren't any perhaps you could explicitly point that out. (When I read the question that was the first thing I wondered...) – TTT Nov 4 '18 at 15:17
  • The passage you are quoting from the IRS publication is not entirely clear to me. "If either spouse has family HDHP coverage, both spouses are treated as having family HDHP coverage." This is clear. "If each spouse has family coverage under a separate plan, the contribution limit for 2017 is $6,750." Why this sentence? What is the contribution limit when they have coverage under the same plan? Furthermore, the section on employer contributions just states that contributions are limited by amount that employer contributes. This does not necessarily imply that one cannot take a full deduction. – NingNing Nov 4 '18 at 15:45
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    @NingNing The deduction is limited to the same amount for the couple whether they share a plan or have separate plans. The pub is just explicitly pointing out different scenarios and stating the rules for those scenarios in an attempt to be clear. – Ben Miller - Reinstate Monica Nov 5 '18 at 2:15
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    @NingNing For the section on employer contributions: The contribution limit applies to money you put in and money that your employer puts in. If the employer kicks in $500, then you have $500 less of contribution limit to use. The deduction only applies to the amount that you put in yourself, not the amount that your employer puts in. Why? Because the amount your employer puts in was never added as part of you income on your W-2. It is, in a sense, automatically deducted before you even begin your return, so you can’t deduct it on your return. (continued...) – Ben Miller - Reinstate Monica Nov 5 '18 at 2:20
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    @NingNing This also applies to contributions made through your employer via payroll deduction, which is what the last sentence in my quote is referring to. If you do all your contributing through payroll deduction and don’t send any money in yourself, your HSA deduction on your tax return is zero, because the amount you contributed through payroll deduction is automatically deducted on your W-2. – Ben Miller - Reinstate Monica Nov 5 '18 at 2:24

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