Proposed Tuition Reporting Regs Lack Insight, Universities Say

While efforts to improve the quality and consistency of information provided to students and families, the Treasury, and the IRS, on Form 1098-T, "Tuition Statement," are laudable, ASU writes to express concern regarding the administrative burden of certain proposed regulations relative to the benefit provided. Since the inauguration of the Form 1098-T reporting requirement, ASU has expended substantial resources to support the complex processes and data required for accurate generation of Form 1098-T. The proposed regulations will require substantial further updates and changes within a relatively short period of time. In light of the continuing discussion of proposed regulations, which may not be finalized until calendar 2017, further extension of the delay in imposition of penalties under section 6721 or 6722 solely because the institution reports the amount billed for QTRE rather than the amount paid, appears warranted.

For the most recent tax year, 2015, ASU issued in excess of 118,000 1098-T Tuition Statements, each of which potentially reflected a unique set of circumstances and activity. In the attached we have provided input and specific concerns regarding the proposed regulations, which in some cases do not appear to fully appreciate the complexity of higher education business practices.

Thank you.