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The Internal Revenue Service should postpone for one year the effective date of a provision enacted late last year requiring institutions to report amounts paid for qualified tuition and expenses in Box 1 of Form 1098-T, NACUBO President and CEO John Walda urged in a January 21 letter to the IRS.

On December 18, 2015, the Consolidated Appropriations Act of 2016 was enacted, amending the Internal Revenue Code to eliminate the option of reporting amounts billed for qualified tuition and expenses in Box 2. Mandated Box 1 reporting is effective for 2016 forms that will be filed in early 2017. NACUBO is aware that a majority of campuses are currently reporting amounts billed in Box 2.

NACUBO's letter asked the IRS to:

  • Publish immediate interim guidance announcing a one-year delay of implementation of the changes to tuition reporting methodology.  There is not sufficient time for institutions that need to make the switch to convert existing data collection and tuition reporting systems for the 2016 year as it is well underway.
  • Develop guidance addressing the new requirement.

NACUBO is closely monitoring this issue and is preparing advice for member institutions. NACUBO will keep members informed of any actions taken by the IRS. 


Mary Bachinger

Director, Tax Policy


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