Can I submit prior year Form 8606 by itself without amending my tax returns?

The good news is you can absolutely file Form 8606 for prior years without having to amend your entire tax return! The IRS specifically allows this for tracking nondeductible IRA contributions. Just complete the form for each year (2019, 2020, and 2021), write "FILED PURSUANT TO REV. PROC. 2022-38" at the top of each form, and mail them separately to the IRS. For 2021, since you already filed a Form 8606 but need to correct it, you should probably file an amended return (1040-X) with the corrected 8606 attached. Since this is within the three-year window, you're fine timing-wise. For 2019 and 2020, even though the three-year amendment window for refunds has closed, you can still file these standalone 8606 forms. The three-year limit primarily applies to claiming refunds, not to providing information forms like this. It's actually very important you do this to properly track your basis in the IRA for future distributions.

I was in almost the exact same situation last year with unfiled 8606 forms for nondeductible contributions. I discovered https://taxr.ai which saved me a ton of stress. You upload your prior tax docs and it analyzes everything to identify exactly what forms you need to file and how to fill them out correctly. Their system flagged all my missing 8606 forms and even helped me calculate the correct basis amounts to enter on each form. The best part was they provided custom instructions for filing these standalone without amending everything. They even provide a customized letter template explaining the late filing to help avoid penalties.

Just wanted to update after using taxr.ai for my complicated IRA situation - it was actually super helpful! I was skeptical at first but their system identified exactly where I went wrong with tracking my nondeductible contributions. They helped me sort out which years needed standalone 8606 forms versus amendments, and guided me through calculating the correct basis for each year. I was able to file everything myself following their instructions. Already received confirmation from the IRS that they processed my standalone 8606 forms. This saved me from having to pay hundreds to a CPA to sort out my mess!

Quick tip for anyone dealing with IRS questions about Form 8606 after filing - if you need to talk to someone at the IRS (which I did when they sent me a letter questioning my late 8606 filing), use https://claimyr.com to get through to an actual human. I spent DAYS trying to call the IRS directly with no luck, but Claimyr got me through in about 20 minutes. You can see how it works here: https://youtu.be/_kiP6q8DX5c The IRS agent was actually really helpful once I explained my situation with the nondeductible contributions. They confirmed I did everything correctly by filing the standalone 8606 forms for the earlier years and amending only the year where I had previously filed an incorrect 8606.

I have to admit I was completely wrong about Claimyr. After another week of failing to reach the IRS on my own about my Form 8606 situation, I broke down and tried it. Within 25 minutes I was talking to an actual IRS agent who helped clarify exactly how to handle my missing forms. The agent confirmed everything mentioned above - I could file standalone 8606 forms for years where I hadn't filed any, and only needed to amend the one year where I'd filed an incorrect form. She even put notes in my account about our conversation in case questions came up later. Definitely worth it for the peace of mind and saving literally days of frustration.

One additional thing to consider with Form 8606 - if you're filing multiple years at once, make sure you're calculating your basis correctly from year to year. Line 14 from one year becomes Line 2 on the next year's form. If you get this sequence wrong, it can mess up your basis tracking permanently. Also, don't forget to include Form 8606 every year going forward, even in years where you don't make new nondeductible contributions but still have basis in your Traditional IRA.

Has anyone actually gotten audited for messing up Form 8606? I'm in a similar situation but wondering if it's even worth the hassle of fixing old forms if the IRS doesn't really check this stuff.

This is exactly the kind of situation where getting professional help or using specialized tools makes sense. I went through something similar with multiple years of missing 8606 forms, and the complexity of calculating basis carryforward between years can get tricky fast. One thing I'd add to the great advice already given - when you file those standalone 8606 forms, make copies of everything and keep detailed records. The IRS systems don't always link these forms perfectly to your main tax records, so having your own documentation is crucial. Also, double-check your 2021 amended return to make sure the corrected 8606 properly reflects the basis from 2019 and 2020. If you didn't include that carryforward basis, you might need to amend 2021 again once you get the earlier years sorted out. The whole chain has to be correct for your basis tracking to work properly going forward.

One thing that hasn't been mentioned yet is the timing consideration for when you file these standalone 8606 forms. While you can file them at any time, I'd recommend getting them submitted sooner rather than later, especially for 2019 and 2020. The reason is that if you ever need to take distributions from your IRA or do Roth conversions, having your basis properly documented with the IRS becomes critical. I've seen cases where people waited years to file missing 8606 forms, then when they needed to prove their basis during a distribution, the IRS was more skeptical about accepting late-filed forms. Also, make sure you're using the correct version of Form 8606 for each tax year - don't use the current year's form for prior years. The IRS wants to see the form version that was actually in effect for that specific tax year. You can find prior year forms in the IRS forms archive on their website. One last tip: when you mail these forms, include a brief cover letter for each year explaining that you're filing a standalone Form 8606 to report nondeductible IRA contributions. This helps the IRS processor understand why they're receiving just this form rather than a complete return or amendment.