How to claim HSA investments on my taxes (Cali)

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corytrevor2
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How to claim HSA investments on my taxes (Cali)

Post by corytrevor2 » Fri Feb 14, 2020 4:57 pm

Hi all, new here!
Background: Live/work in California. Have had HSA for the last couple years, just started investing it toward the end of 2019. A friend recommended I put it in treasuries, that way California won't tax me on any gains/dividends.
Question: Doing my taxes for 2019 now and wondering how I claim this properly on my taxes. My W2 covers my contributions, so that part I understand. But, in terms of interest/dividends received on treasury holdings in my HSA, how do I claim it properly on my taxes? Using either TurboTax or 1040.com for my taxes FYI.
Thanks in advance!
CT2

Teague
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Re: How to claim HSA investments on my taxes (Cali)

Post by Teague » Fri Feb 14, 2020 6:06 pm

Welcome!

I'm going to presume you are a fairly high earner, so sure, always nice to avoid state tax at 9.3%. (I presume this noting your use of the term "Cali" which suggests you are not a native. I'd guess you probably relocated here for a job, which would have to pay pretty well to get most folks to move to a HCOL area.)

But I'm not sure you're going to accomplish what you set out to do by going this route. See:
https://thefinancebuff.com/california-n ... eturn.html
Semper Augustus

SurfCityBill
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Re: How to claim HSA investments on my taxes (Cali)

Post by SurfCityBill » Fri Feb 14, 2020 6:34 pm

Teague wrote:
Fri Feb 14, 2020 6:06 pm
Welcome!

I'm going to presume you are a fairly high earner, so sure, always nice to avoid state tax at 9.3%. (I presume this noting your use of the term "Cali" which suggests you are not a native. I'd guess you probably relocated here for a job, which would have to pay pretty well to get most folks to move to a HCOL area.)

But I'm not sure you're going to accomplish what you set out to do by going this route. See:
https://thefinancebuff.com/california-n ... eturn.html
Excellent link. I wish I was aware of this years ago. Thank you for sharing.

ofckrupke
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Re: How to claim HSA investments on my taxes (Cali)

Post by ofckrupke » Fri Feb 14, 2020 6:48 pm

corytrevor2 wrote:
Fri Feb 14, 2020 4:57 pm
in terms of interest/dividends received on treasury holdings in my HSA, how do I claim it properly on my taxes? Using either TurboTax or 1040.com for my taxes FYI.
I have no idea how to get TT or other software to jump the hoops, but interest on bonds should show up as an addition on Schedule CA (540) on line 2b column C (year 2019 line numbering), and dividends should show up on line 3b column C. Income from both individual bond interest and fund dividends that would be state-exempt even if it weren't in an HSA should also be merged into a single subtraction column cell at line 2b, column B.
Even if the HSA income is 100% due to state exempt treasury interest and dividends, both the additions and offsetting subtraction should be reported.

CFM300
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Re: How to claim HSA investments on my taxes (Cali)

Post by CFM300 » Fri Feb 14, 2020 6:55 pm

corytrevor2 wrote:
Fri Feb 14, 2020 4:57 pm
in terms of interest/dividends received on treasury holdings in my HSA, how do I claim it properly on my taxes?
You'll need to file Schedule CA with your California return.

On line 1 (Part I, section A), you'll add your $6,000 HSA contribution (or whatever's shown on your W2).

If you had interest or dividends from non-treasury sources, then you'd add that on line 2 or 3. Double-check what you're invested in and be sure that it's exempt from CA state tax.

Be careful making periodic investments and reinvesting dividends because you'll need to track the cost basis of each purchase to report the gains to California when you sell.

A common strategy is to let contributions and dividends accumulate in a Treasury-only money market and then make a single annual purchase of a Treasury-only bond fund.

See this and other threads: viewtopic.php?t=279583

CFM300
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Re: How to claim HSA investments on my taxes (Cali)

Post by CFM300 » Fri Feb 14, 2020 7:24 pm

ofckrupke wrote:
Fri Feb 14, 2020 6:48 pm
interest on bonds should show up as an addition on Schedule CA (540) on line 2b column C (year 2019 line numbering), and dividends should show up on line 3b column C. Income from both individual bond interest and fund dividends that would be state-exempt even if it weren't in an HSA should also be merged into a single subtraction column cell at line 2b, column B.
Even if the HSA income is 100% due to state exempt treasury interest and dividends, both the additions and offsetting subtraction should be reported.
Are you sure about the need to add and subtract the dividends from investments that are exempt from California taxes?

I read the instructions for Schedule CA, line 3 and they don't mention this sort of double entry.

Would someone who had dividends from a Vanguard California Tax-exempt fund in a regular taxable account also have to do this double entry?

TurboTax certainly doesn't do it by default. I would have to enter the information manually, even though TurboTax downloaded the 1099-DIV info from Vanguard.

ofckrupke
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Re: How to claim HSA investments on my taxes (Cali)

Post by ofckrupke » Fri Feb 14, 2020 8:12 pm

CFM300 wrote:
Fri Feb 14, 2020 7:24 pm
ofckrupke wrote:
Fri Feb 14, 2020 6:48 pm
interest on bonds should show up as an addition on Schedule CA (540) on line 2b column C (year 2019 line numbering), and dividends should show up on line 3b column C. Income from both individual bond interest and fund dividends that would be state-exempt even if it weren't in an HSA should also be merged into a single subtraction column cell at line 2b, column B.
Even if the HSA income is 100% due to state exempt treasury interest and dividends, both the additions and offsetting subtraction should be reported.
Are you sure about the need to add and subtract the dividends from investments that are exempt from California taxes?

I read the instructions for Schedule CA, line 3 and they don't mention this sort of double entry.

Would someone who had dividends from a Vanguard California Tax-exempt fund in a regular taxable account also have to do this double entry?
The reasoning behind offsetting, nonzero entries for US Govt debt interest income in an HSA is that there are two separate issues of divergence from federal treatment. The reason an addition should be reported is that CA does not consider HSAs as tax-advantaged accounts. The reason a subtraction should be reported is that while US Govt debt interest income is federally taxable and would have shown up in line 3b column A if HSAs were not federally tax advantaged, it is CA-exempt. (See the instructions for columns B and C, section A, line 2...for treasury fund dividends it's the paragraph beginning "Certain mutual funds...")

Now as to the question about dividends from federally-exempt, CA-exempt interest from a CA muni fund: here the federal exempt income would get reported on Schedule CA line 2a (and not in 3b column A, although any incidental federally-non-exempt portion would), in conformity with its treatment on form 1040. Only the portion of such dividends attributable to federally-exempt-but-not-CA-exempt bonds (for instance, munis from other states) would get reported on line 3b column C (unless the fund failed the 50%-CA-exempt asset percentage test, in which case why did they call it a CA tax-exempt fund anyway).

So I suppose I should have sharpened up the qualifications/restrictions for the cited passage. I didn't really mean to address cases outside the OP's narrow question concerning treasury income in an HSA (for a CA resident, I hope at least this part is clear from context).

A third variant is now often found in short-term bond index funds, which at least recently have tended to be >50% treasuries so pass CA's asset threshold test. All of the dividend income goes to line 3b column A, nothing to column C, and the portion attributable to treasuries, assuming the CA asset test was met, again goes to line 2b column B.

CFM300
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Re: How to claim HSA investments on my taxes (Cali)

Post by CFM300 » Fri Feb 14, 2020 8:22 pm

ofckrupke wrote:
Fri Feb 14, 2020 8:12 pm
The reasoning behind offsetting, nonzero entries for US Govt debt interest income in an HSA is that...

(See the instructions for columns B and C, section A, line 2...for treasury fund dividends it's the paragraph beginning "Certain mutual funds...")
By golly, I think you're right! I'm going to have to study this more.

Thanks.

ofckrupke
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Re: How to claim HSA investments on my taxes (Cali)

Post by ofckrupke » Fri Feb 14, 2020 9:21 pm

ofckrupke wrote:
Fri Feb 14, 2020 8:12 pm
A third variant is now often found in short-term bond index funds, which at least recently have tended to be >50% treasuries so pass CA's asset threshold test. All of the dividend income goes to line 3b column A, nothing to column C, and the portion attributable to treasuries, assuming the CA asset test was met, again goes to line 2b column B.
...unless it's in a HSA for a CA resident, in which case none of it shows up in 3b column A, all of it shows as an addition in 3b column C, and the treasury/exempt-agency portion (again assuming the CA-exempt asset % test is satisfied) goes to line 2b column B. (Just trying to circle back to the concerns of the OP and topic title...)

CFM300
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Re: How to claim HSA investments on my taxes (Cali)

Post by CFM300 » Sat Feb 15, 2020 1:25 pm

CFM300 wrote:
Fri Feb 14, 2020 8:22 pm
ofckrupke wrote:
Fri Feb 14, 2020 8:12 pm
The reasoning behind offsetting, nonzero entries for US Govt debt interest income in an HSA is that...

(See the instructions for columns B and C, section A, line 2...for treasury fund dividends it's the paragraph beginning "Certain mutual funds...")
By golly, I think you're right! I'm going to have to study this more.

Thanks.
Previously, I posted a question about calculating and reporting HSA dividends on California taxes and no one mentioned doing double-entry adjustments as you have. In fact, many suggested that investing directly in Treasury bonds eliminated the need to report dividends. I think that's where I got the idea that I also wouldn't need to report dividends if they were all California tax-exempt, even if from a mutual fund.

viewtopic.php?t=279583

ofckrupke
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Re: How to claim HSA investments on my taxes (Cali)

Post by ofckrupke » Sat Feb 15, 2020 2:26 pm

Yeah, I don't think you were perfectly served in that topic, but I do think that the ledger and tax accounting for autorolled t-bills at Fidelity would still be appreciably easier than what I am going through at (employer-chosen) HealthEquity to hold VIPIX - a TIPS fund and for my purposes still the cleanest shirt in the available pile. Notably, reinvestment of distributions is automatic and mandatory at HE, but they don't show the distributions/reinvestment events...because from their point of view why bother, "it's a tax advantaged account", I suppose. Thus, in order to maintain a self-consistent personal ledger of individual lots against chance of FTB audit following their future disposition, a CA taxpayer must infer the dates and dollar amounts from the difference in share counts before and after each fund distribution - assisted by Vanguard's distribution numbers and share prices on and shortly after Vanguard's reinvestment date. At least once, a self-consistent ledger entry for the new CA tax lot was arrived at only under hypothesis that the reinvestment at/by HE occurred at a different date and thus at a different share price than those published by Vanguard. And I have lucked out, comparatively speaking, since VIPIX has not distributed any capital gains while I've held it (definitely touching wood here); such pit awaits no one autorolling t-bills in their CA HSA, provided they sell no unmatured bills.

CFM300
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Re: How to claim HSA investments on my taxes (Cali)

Post by CFM300 » Sat Feb 15, 2020 3:15 pm

ofckrupke wrote:
Sat Feb 15, 2020 2:26 pm
Yeah, I don't think you were perfectly served in that topic, but I do think that the ledger and tax accounting for autorolled t-bills at Fidelity would still be appreciably easier than what I am going through at (employer-chosen) HealthEquity to hold VIPIX - a TIPS fund and for my purposes still the cleanest shirt in the available pile.
Really appreciate your continued responses, and yeah, it sounds like your HSA provider is making things quite challenging for you. My situation is easier, since I'm only investing in two funds, FDLXX and FUAMX. Dividends from the former are 100% CA tax-exempt, while divs from the latter are nearly so (99.83% in 2019, I think).

Final question (I hope!) about this:

Do the dividends get added and subtracted on line 2 of Schedule CA? That's where HSA's are explicitly mentioned in the instructions. But technically, line 2 is for interest, not dividends. Dividend adjustments are supposed to go on line 3, but there's no mention of HSA's in the instructions for line 3. Which is what I think also led me to believe originally that I didn't even need to report them.

TurboTax, in interview mode, only allows one to add amounts, not subtract. That might be why some Bogleheads are thinking that only a net addition is required, not a double-entry.

Thanks again for all of your help.

ofckrupke
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Re: How to claim HSA investments on my taxes (Cali)

Post by ofckrupke » Sat Feb 15, 2020 3:55 pm

CFM300 wrote:
Sat Feb 15, 2020 3:15 pm
Do the dividends get added and subtracted on line 2 of Schedule CA?
In this case, 100% of fund dividends get added in 3b column C. The 99.9n% owing to US Govt obligation interest gets subtracted in 2b column B.

Not putting offsetting entries on the same row is a little weird the first time, but 1) this makes no difference once you sum each column on line 9 and 2) it rhymes with the way federally exempt muni fund dividends show up in form 1040 on line 2a, even though non-exempt fund dividends, even arising from debt interest, show up on line 3b rather than 2b.

For me, it was easy to dismiss the possible implication in the expansive "other earnings" wording in the schedule CA instructions by reminding myself that the thing about income from an HSA as far as CA is concerned is that it's just another taxable account. If HSAs weren't federally tax advantaged then (non-muni) dividends would show up in 3b on the federal return, and thus on line 3b column A of schedule CA. Additions relative to 3b col A arising from different taxation law belong on 3b col C. [If I instead had individual treasuries in an HSA, then I'd put their interest income in line 2b col C before subtracting it out in col B, because in that case, line 2b is where the interest would show up on the federal return if HSAs weren't federally tax advantaged. ]
I hope that makes sense to you, although I probably shouldn't expect an FTB auditor to be equally open minded - surviving in their job requires subservience to the coders of their workflow software. But even that probably directs its user that if the numbers in schedule CA line 9 don't change, then just move on.

CFM300
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Re: How to claim HSA investments on my taxes (Cali)

Post by CFM300 » Sat Feb 15, 2020 4:38 pm

ofckrupke wrote:
Sat Feb 15, 2020 3:55 pm
In this case, 100% of fund dividends get added in 3b column C. The 99.9n% owing to US Govt obligation interest gets subtracted in 2b column B.

Not putting offsetting entries on the same row is a little weird the first time, but...
Thanks yet again for your detailed reply. Much appreciated. :beer

manatee2005
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Re: How to claim HSA investments on my taxes (Cali)

Post by manatee2005 » Sat Feb 15, 2020 11:46 pm

Teague wrote:
Fri Feb 14, 2020 6:06 pm
Welcome!

I'm going to presume you are a fairly high earner, so sure, always nice to avoid state tax at 9.3%. (I presume this noting your use of the term "Cali" which suggests you are not a native. I'd guess you probably relocated here for a job, which would have to pay pretty well to get most folks to move to a HCOL area.)

But I'm not sure you're going to accomplish what you set out to do by going this route. See:
https://thefinancebuff.com/california-n ... eturn.html
Nice detective work :-) Book 'em Danno!

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billthecat
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Re: How to claim HSA investments on my taxes (Cali)

Post by billthecat » Sat Feb 15, 2020 11:52 pm

CFM300 wrote:
Fri Feb 14, 2020 6:55 pm
corytrevor2 wrote:
Fri Feb 14, 2020 4:57 pm
in terms of interest/dividends received on treasury holdings in my HSA, how do I claim it properly on my taxes?
You'll need to file Schedule CA with your California return.

On line 1 (Part I, section A), you'll add your $6,000 HSA contribution (or whatever's shown on your W2).

If you had interest or dividends from non-treasury sources, then you'd add that on line 2 or 3. Double-check what you're invested in and be sure that it's exempt from CA state tax.

Be careful making periodic investments and reinvesting dividends because you'll need to track the cost basis of each purchase to report the gains to California when you sell.

A common strategy is to let contributions and dividends accumulate in a Treasury-only money market and then make a single annual purchase of a Treasury-only bond fund.

See this and other threads: viewtopic.php?t=279583
I invest in VTSAX (Vanguard total market mutual fund) in my California HSA, in addition to a minimum level of cash I have to maintain. I haven't sold any shares. Looking up the interest (on the cash) and the dividends received (from VTSAX) is easy enough, but how am I supposed to know what capital gains the fund had (inside the fund)?
We cannot direct the winds but we can adjust our sails.

manatee2005
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Re: How to claim HSA investments on my taxes (Cali)

Post by manatee2005 » Sun Feb 16, 2020 1:54 am

billthecat wrote:
Sat Feb 15, 2020 11:52 pm
CFM300 wrote:
Fri Feb 14, 2020 6:55 pm
corytrevor2 wrote:
Fri Feb 14, 2020 4:57 pm
in terms of interest/dividends received on treasury holdings in my HSA, how do I claim it properly on my taxes?
You'll need to file Schedule CA with your California return.

On line 1 (Part I, section A), you'll add your $6,000 HSA contribution (or whatever's shown on your W2).

If you had interest or dividends from non-treasury sources, then you'd add that on line 2 or 3. Double-check what you're invested in and be sure that it's exempt from CA state tax.

Be careful making periodic investments and reinvesting dividends because you'll need to track the cost basis of each purchase to report the gains to California when you sell.

A common strategy is to let contributions and dividends accumulate in a Treasury-only money market and then make a single annual purchase of a Treasury-only bond fund.

See this and other threads: viewtopic.php?t=279583
I invest in VTSAX (Vanguard total market mutual fund) in my California HSA, in addition to a minimum level of cash I have to maintain. I haven't sold any shares. Looking up the interest (on the cash) and the dividends received (from VTSAX) is easy enough, but how am I supposed to know what capital gains the fund had (inside the fund)?
Why would you have to ay the capital gains inside the fund? You wouldn't get 1099B for that in a regular account, why do you think you need to report that for HSA?

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billthecat
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Re: How to claim HSA investments on my taxes (Cali)

Post by billthecat » Sun Feb 16, 2020 10:24 am

manatee2005 wrote:
Sun Feb 16, 2020 1:54 am
billthecat wrote:
Sat Feb 15, 2020 11:52 pm
CFM300 wrote:
Fri Feb 14, 2020 6:55 pm
corytrevor2 wrote:
Fri Feb 14, 2020 4:57 pm
in terms of interest/dividends received on treasury holdings in my HSA, how do I claim it properly on my taxes?
You'll need to file Schedule CA with your California return.

On line 1 (Part I, section A), you'll add your $6,000 HSA contribution (or whatever's shown on your W2).

If you had interest or dividends from non-treasury sources, then you'd add that on line 2 or 3. Double-check what you're invested in and be sure that it's exempt from CA state tax.

Be careful making periodic investments and reinvesting dividends because you'll need to track the cost basis of each purchase to report the gains to California when you sell.

A common strategy is to let contributions and dividends accumulate in a Treasury-only money market and then make a single annual purchase of a Treasury-only bond fund.

See this and other threads: viewtopic.php?t=279583
I invest in VTSAX (Vanguard total market mutual fund) in my California HSA, in addition to a minimum level of cash I have to maintain. I haven't sold any shares. Looking up the interest (on the cash) and the dividends received (from VTSAX) is easy enough, but how am I supposed to know what capital gains the fund had (inside the fund)?
Why would you have to ay the capital gains inside the fund? You wouldn't get 1099B for that in a regular account, why do you think you need to report that for HSA?
Because funds that buy and sell the underlying investments pass through capital gains to the fund holder? Why wouldn't you get a 1099-B in a regular account?

https://www.thebalance.com/mutual-fund- ... ns-2466692

"Mutual fund capital gains distributions are taxable events resulting from the fund's manager selling shares of securities held within the fund....these capital gains distributions result in a tax bill if you own mutual funds in a taxable account."
We cannot direct the winds but we can adjust our sails.

lstone19
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Re: How to claim HSA investments on my taxes (Cali)

Post by lstone19 » Sun Feb 16, 2020 8:25 pm

billthecat wrote:
Sun Feb 16, 2020 10:24 am
manatee2005 wrote:
Sun Feb 16, 2020 1:54 am

Why would you have to ay the capital gains inside the fund? You wouldn't get 1099B for that in a regular account, why do you think you need to report that for HSA?
Because funds that buy and sell the underlying investments pass through capital gains to the fund holder? Why wouldn't you get a 1099-B in a regular account?

https://www.thebalance.com/mutual-fund- ... ns-2466692

"Mutual fund capital gains distributions are taxable events resulting from the fund's manager selling shares of securities held within the fund....these capital gains distributions result in a tax bill if you own mutual funds in a taxable account."
You have apparently missed the word "distributions" in the sentence above. Until and unless the fund makes a capital gains distribution, you as a mutual fund shareholder have no taxable event for capital gains inside the fund. Capital gains distributions for a taxable account are reported on 1099-DIV (box 2a for long-term, box 1 for short-term), not 1099-B.

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grabiner
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Re: How to claim HSA investments on my taxes (Cali)

Post by grabiner » Sun Feb 16, 2020 9:51 pm

lstone19 wrote:
Sun Feb 16, 2020 8:25 pm
billthecat wrote:
Sun Feb 16, 2020 10:24 am
manatee2005 wrote:
Sun Feb 16, 2020 1:54 am

Why would you have to ay the capital gains inside the fund? You wouldn't get 1099B for that in a regular account, why do you think you need to report that for HSA?
Because funds that buy and sell the underlying investments pass through capital gains to the fund holder? Why wouldn't you get a 1099-B in a regular account?

https://www.thebalance.com/mutual-fund- ... ns-2466692

"Mutual fund capital gains distributions are taxable events resulting from the fund's manager selling shares of securities held within the fund....these capital gains distributions result in a tax bill if you own mutual funds in a taxable account."
You have apparently missed the word "distributions" in the sentence above. Until and unless the fund makes a capital gains distribution, you as a mutual fund shareholder have no taxable event for capital gains inside the fund. Capital gains distributions for a taxable account are reported on 1099-DIV (box 2a for long-term, box 1 for short-term), not 1099-B.
But you could get these in a Treasury fund held in your HSA. When interest rates fall, bond prices rise, and Treasury funds may sell bonds for a capital gain. In CA, these capital gains are still taxable. (In NJ, the other state which does not recognize HSAs, capital gains from Treasuries are not taxable.)
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crystalbank
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Re: How to claim HSA investments on my taxes (Cali)

Post by crystalbank » Sun Feb 16, 2020 9:55 pm

billthecat wrote:
Sun Feb 16, 2020 10:24 am
manatee2005 wrote:
Sun Feb 16, 2020 1:54 am
billthecat wrote:
Sat Feb 15, 2020 11:52 pm
CFM300 wrote:
Fri Feb 14, 2020 6:55 pm
corytrevor2 wrote:
Fri Feb 14, 2020 4:57 pm
in terms of interest/dividends received on treasury holdings in my HSA, how do I claim it properly on my taxes?
You'll need to file Schedule CA with your California return.

On line 1 (Part I, section A), you'll add your $6,000 HSA contribution (or whatever's shown on your W2).

If you had interest or dividends from non-treasury sources, then you'd add that on line 2 or 3. Double-check what you're invested in and be sure that it's exempt from CA state tax.

Be careful making periodic investments and reinvesting dividends because you'll need to track the cost basis of each purchase to report the gains to California when you sell.

A common strategy is to let contributions and dividends accumulate in a Treasury-only money market and then make a single annual purchase of a Treasury-only bond fund.

See this and other threads: viewtopic.php?t=279583
I invest in VTSAX (Vanguard total market mutual fund) in my California HSA, in addition to a minimum level of cash I have to maintain. I haven't sold any shares. Looking up the interest (on the cash) and the dividends received (from VTSAX) is easy enough, but how am I supposed to know what capital gains the fund had (inside the fund)?
Why would you have to ay the capital gains inside the fund? You wouldn't get 1099B for that in a regular account, why do you think you need to report that for HSA?
Because funds that buy and sell the underlying investments pass through capital gains to the fund holder? Why wouldn't you get a 1099-B in a regular account?

https://www.thebalance.com/mutual-fund- ... ns-2466692

"Mutual fund capital gains distributions are taxable events resulting from the fund's manager selling shares of securities held within the fund....these capital gains distributions result in a tax bill if you own mutual funds in a taxable account."
VTSAX along with many Vanguard's Tax Efficient Funds don't usually distribute Capital Gains. If they do distribute Capital Gains, you'll see them as a transaction in your account. If the fund doesn't distribute anything to you then you don't have to report anything.

ofckrupke
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Re: How to claim HSA investments on my taxes (Cali)

Post by ofckrupke » Sun Feb 16, 2020 10:25 pm

crystalbank wrote:
Sun Feb 16, 2020 9:55 pm
If they do distribute Capital Gains, you'll see them as a transaction in your account.
Not at HealthEquity. There, new money share transactions show but distribution&reinvestment don't; the share count will just silently change at or slightly after the fund provider's reinvestment date. So a CA accountholder needs to anticipate the distribution and record share count before and after. Since HE doesn't always reinvest in sync with the provider, and doesn't always update the share count in sync with the reinvestment, one sometimes needs to extract share price data from the provider for a handful of days after the distribution in order to reconcile the dollar amount that should have been distributed against the count of new shares in the HE account. If the distribution contains CG components to be reported and/or taxed differently from dividend income (dividends from treasury income are exempt) under CA tax law, this needs to be split out by hand by the accountholder as well, using the fund provider's distribution records. PITA.

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