Tax Brief Issue 8: 2027 HSA Limits, Bonus Depreciation/R&D Relief, Inherited IRAs, S-Corp Errors

01. 2027 HSA and HDHP Inflation Adjustments

• For calendar year 2027, the annual Health Savings Account (HSA) contribution limitation is $4,500 for self-only coverage and $9,000 for family coverage.
• For calendar year 2027, a high deductible health plan (HDHP) has a minimum annual deductible of $1,750 for self-only coverage or $3,500 for family coverage, and maximum annual out-of-pocket expenses of $8,700 for self-only or $17,400 for family coverage.

Source: IRS Internal Revenue Bulletin · 2026-06-15

02. Late Bonus Depreciation & R&D Election Relief

• The IRS granted a taxpayer an extension of time to make a Section 168(k)(7) election and file a Form 3115 for a Section 174 accounting method change, despite an untimely federal income tax return.

Source: IRS Written Determinations · 2026-06-12

03. Estate Inherited IRA RMD and Transfers

• Individual beneficiaries of an estate that inherited an IRA may establish separate inherited IRAs and use the decedent's remaining life expectancy for required minimum distributions, provided the decedent died after their required beginning date and the estate was the IRA's sole beneficiary.
• A trustee-to-trustee transfer to segregate an IRA inherited by an estate into separate inherited IRAs for individual estate beneficiaries does not constitute a taxable distribution or a rollover.

Source: IRS Written Determinations · 2026-06-12

04. S-Corp and QSub Inadvertent Invalid Election Relief

• An LLC electing S corporation status can create a disqualifying second class of stock if its operating agreement includes partnership-style provisions such as special allocations or profit interests.
• The IRS can grant inadvertent invalid election relief under IRC Section 1362(f) for both an S corporation election and a Qualified Subchapter S Subsidiary (QSub) election.

Source: IRS Written Determinations · 2026-06-12