I assume there will be carryover from 2020. I agree with Lisa in that I will not transfer any clients until beginning of 2nd week of Jan. I know some transfer only as their client comes in but I transfer all when I do. 

What do you think I'll need to do about the ones who filed prior to the 8915 being available in 2020?  I had to attach it to the return.  Do you think they will continue the 10% early withdrawal exemption in 2021?

You may have to pull up the 2021 form 8915 and fill it in yourself for those that you had attached the form.

As far as the early w/d penalty for 2021, who knows what might change by the time we're able to file, as of right now, the penalty applies.

For the 2020 returns filed prior to the 8915 being available  - why not open the return now and complete the 8915 as submitted.   Then it will be there to carryforward to the 2021 return.