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Business and Policy Areas
Business and Policy Areas

NACUBO Provides Advice on Collecting Student TINs

October 1, 2014

Colleges and universities need to collect students' taxpayer identification numbers (TINs) in order to meet their obligations to report tuition payments on Internal Revenue Service Form 1098-T. If they don't have the correct number, IRS regulations require institutions to solicit one at least once a year in order to avoid fines. After the IRS sent notices of proposed fines to hundreds of campuses in 2013, and again this year, institutions have focused more on the best ways to ensure compliance. NACUBO Advisory Report 2014-1, Collecting Taxpayer Identification Numbers for Form 1098-T Reporting, provides advice on best practices, relevant regulations, and model substitute W-9S forms. The advice was developed by a joint subcommittee of NACUBO's Student Financial Services and Tax Councils, with assistance from representatives from the American Association of Collegiate Registrars and Admissions Officers.

Substitute W-9S Forms

The IRS created Form W-9S, Request for Student's or Borrower's Taxpayer Identification Number and Certification, for institutions and lenders to use to collect the TINs needed for filling 1098-E and 1098-T. For several reasons enumerated in Advisory Report 2014-1, Form W-9S does not always meet the needs of institutions. NACUBO has prepared two sample substitute forms which members are welcome to use or modify further. Links in the report lead to these forms in Microsoft Word to allow the school name and other information to be added. 


Anne Gross
Vice President, Regulatory Affairs

Mary Bachinger
Director, Tax Policy