Date of Request Authorizing Contribution to IRA Treated as Contribution Date, IRS Concludes The IRS has concluded, in a private letter ruling (LTR 201437023), that the date of an irrevocable letter of authorization (LOA) sent by an individual to a financial services company, instructing the company to transfer funds from a non-retirement account to an IRA, will be treated as the date of the contribution. Accordingly, if the LOA is postmarked by April 15, or if the client makes a documented verbal request to the company by April 15, the taxpayer is deemed to have made the contribution by the end of the preceding year. CCH Take Away. Generally, a contribution to an IRA must be made by the due date of the taxpayer’s return, without extensions, for the year that the contribution is claimed. Here, even though the actual transfer of funds could take place after April 15, the IRS treated the date of an irrevocable authorization as the contribution date. The IRS previously ruled, in a 1985 private letter ruling, that the postmark date of a contribution would be treated as the contribution date. Background The company transfers funds from a non-retirement account it holds for an individual to an existing IRA or Coverdell Education Savings Account (CESA). The account holder must submit an LOA in writing, or must make a verbal request to a company representative (summarized in a document signed and dated by the company). The LOA must indicate the amount of the cash contribution, the account from which the funds are being transferred, and the tax year for which the contribution is made. The LOA is irrevocable on receipt. The client must have sufficient funds in his or her account and must have previously established an IRA or CESA with the company. Although the company processes an LOA as soon as administratively practicable, in some cases the transfer is not processed until after April 15, even if it is received by April 15. The IRS agreed that an individual submitting an LOA to the company, under the conditions described, shall be deemed to have made a cash contribution to an IRA or CESA on the last day of the preceding taxable year. The funds must be transferred as soon as administratively practicable, and the IRA or CESA must satisfy Code Sec. 408 or 530, respectively.