The Internal Revenue Service (IRS) has altered Form 1098-T for 2016 to implement the recent statutory change allowing colleges and universities to certify that they have met the regulatory requirements for soliciting student taxpayer identification numbers (TINs) at least once during the year. NACUBO pushed for the change to end the cycle of fine notices schools were receiving for missing or incorrect TINs.
Although it is still unclear how, or if, the IRS will implement the new provision for the 2015 tax year—the 1098-Ts that will be sent to students in January—institutions should ensure that they have met the solicitation requirements. NACUBO's Advisory Report 2014-1, Collecting Taxpayer Identification Numbers for Form 1098-T Reporting, provides the regulations and advice for doing so.
Form 1098-T for 2015 was finalized before the new statutory provision was enacted and has not been changed. The IRS recently released the 2016 form, however, and has added a checkbox for filers to certify that they have complied with the solicitation requirements. The checkbox, which appears only on the copy of the form that is submitted to the IRS, is placed within the box for the student's TIN.
The instructions for the form read:
"Student's taxpayer identification number and checkbox. If you are not able to obtain the student's taxpayer identifying number through the use of Form W-9S, Request for Student's or Borrower's Taxpayer Identification Number and Certification, or other substitute form, check the box. By checking the box and filing Form 1098-T with the IRS (for electronic filers), you certify under penalty of perjury that you have in good faith complied with the standards in regulation section 1.6050S-1 governing the time and manner of soliciting the taxpayer identification numbers of individuals. Filers who transmit paper forms to the IRS will make such certification by signing Form 1096 in conjunction with filing the returns with the boxes checked in the field designated for the student's identification number."
NACUBO will alert members if and when IRS makes any changes related to filing Form 1098-T for 2015.