EDUCAUSE Comments: IRS Form 1098-T Rule-Making

Abstract

(November 16, 2016) EDUCAUSE and nine other higher education associations joined the National Association of College and University Business Officers (NACUBO) in commenting on proposed IRS regulations for Form 1098-T (Tuition Statement) reporting. While the comments largely addressed IRS proposals on various educational tax credits, they also discussed problems that proposed reporting rules would create for enterprise systems. For example, a proposed rule would require institutions to report students’ full-time enrollment status by month. Since institutions generally track enrollment status by academic term, their enterprise systems would not capture enrollment information in the required fashion. Thus, they would likely have to work with their system providers to reprogram relevant systems specifically to meet the new rule, which was not mandated by Congress as part of the laws that led to the rule-making at issue.

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