Legislative Update - July 22, 1998

Higher Education Tax Breaks

On July 22, President Clinton gave his approval to a bill that includes modifications to the reporting requirements for educational institutions for Hope and Lifetime Learning tax credits. The changes to the Taxpayer Relief Act were included in the IRS Restructuring and Reform Act of 1998 (HR 2676) passed by the House on June 25 and just recently by the Senate.

Institutional Reporting Requirements
The change to Internal Revenue Code section 6050S clarifies the reporting of qualified tuition and related expenses. Institutions will be required to report the aggregate amount of qualified tuition and related expenses, grant amounts received for payment of costs of attendance that was processed through the institution, and the aggregate amount of refunds and reimbursements paid by the institution. The conference report language makes it clear that qualified tuition and related expenses should be reported without adjustments for nontaxable grant aid. Many institutions were concerned that regulations would require institutions to apply grants to specific expenses in order to report a net amount on Form 1098-T.

Student Loan Interest Deductibility
The bill modifies Section 221 of the Internal Revenue Code to clarify the provision related to the deductibility of student loan interest. The bill provides that the student loan interest deduction may be claimed only by a taxpayer who is legally obligated to make the interest payments pursuant to the terms of the loan. The provision is effective for interest payments due and paid after December 31, 1997, on any qualified education loan. Further, the bill stipulates that, in the case of multiple loans which are refinanced by, or serviced as, a single loan and in the case of loans incurred before the date of enactment, the Secretary shall prescribe what constitutes the 60 months each loan is eligible for the deduction of interest paid.

The conference report, which does not have the force of law but does provide agencies with insight into congressional intent, also addresses several other issues that have concerned the higher education community, as follows:

Definition of qualified tuition and related expenses
The conferees urge Treasury to conform the definition to that used in section 472(1) of the Higher Education Act, to the extent possible. This is the definition of tuition and fees that is used as part of the calculation of cost of attendance. Exceptions in the statutory language of Code section 25A for expenses relating to sports, games, or hobbies, and nonacademic fees will still apply.

Delay until regulations issued. The change to section 6050S is effective for tax years beginning on or after January 1, 1999. Under IRS Notice 97-73, institutions are not required to report any financial information for 1998. The conference report directs that the effective date on regulations should allow educational institutions sufficient time to implement additional reporting requirements, and that no reporting beyond that specified in Notice 97-73 should be required until final regulatory guidance is available.

Exemptions
The conferees also note that Treasury has the authority to exempt institutions from reporting on certain categories of students, such as "non-degree students enrolled in a course for which academic credit is not granted by the institution," as long as the exemptions do not compromise compliance objectives.

Reporting on parents
The conference report does not address institutions' concerns about reporting on the person who will claim the student as a dependent except to urge that any modernization of IRS computer systems include the capacity to match dependents' taxpayer identification numbers to the taxpayers' returns. Efforts to seek statutory relief from reporting on parents were stymied by the extremely high cost to the federal government associated with the elimination of this requirement.


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