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Until the final regulations are published by the Internal Revenue Service (IRS) with guidance related to 1098-T reporting requirements, colleges and universities should not be required to implement the Box 1 reporting requirement enacted in late 2015, NACUBO President and CEO John Walda urged in a July 21 letter to the agency. Walda requested a one-year postponement of implementation of the changes to the Form 1098-T.

Last fall, NACUBO submitted comprehensive comments to the IRS on the proposed regulations on behalf of the higher education community. Four witnesses from NACUBO member institutions also provided comments on the proposed rules and responded to questions from IRS and Treasury Department officials at the November 30 public hearing.

Since that time, the IRS has been working on final regulations that impact several aspects of 1098-T reporting requirements—including the requirement to report amounts paid for qualified tuition and expenses. However, at this point there is insufficient lead time for college and university systems modifications and testing to occur in order to properly begin collecting and tracking—as of January 1, 2018—new data elements that might be included in the pending final regulations.

It is unclear when final rules can be expected from the IRS. Walda urged the IRS in the meantime to provide guidance clarifying that any new reporting requirements will not be effective for tax year 2018.


Mary Bachinger

Director, Tax Policy


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