I've been submitting 1099Q and 1098T for years. For 2023, I have an unfortunate date situation.
I withdrew from my 529 in July 2023 for 2023 Fall Semester and December 2023 for 2024 Spring Semester. 529 funds go directly to me and I, in turn, pay the college. Unfortunately, the funds to the college did not post until 1/2/2024, so naturally my 2023 1098T from the college only has ONE semester payment. But, my 2023 1099Q has BOTH semester payments. In past years, I was careful to ensure the 529 withdrawls were done in the same year as payments to the college, so the 1099Q and 1098T always had 2 semesters.
How do I handle this situation? Turbotax is obviously taxing me on excess 2023 withdrawls!
You'll need to sign in or create an account to connect with an expert.
Q. I wonder if the 529 provider (Vanguard) will issue me a revised 2023 1099Q ?
A. No. But, you don't need it. You report it as a rollover (if you even report it).
Q. I was questioning whether or not I would really have to do this rollover considering the IRS pub that says: "You must pay the qualified education expenses for an academic period that starts during the tax year or the first three months of the next tax year. "
A. That only means you can pay for the first term of 2024 in Dec. 2023. But, it's questionable if you actually did that (posted 1/2/24).
Q. So I would think this would be ok despite crossing tax years?
A. I agree. It's just that there's no firm evidence of how the IRS might handle it. I think it's a common enough and reasonable situation that they will probably allow it.
Q. But, perhaps better on the safe side and do the rollover/withdrawal?
A. Yes. You have that option. Most of the time that we see this question, the taxpayer has already missed the 60 day window. It might be a minor (and unnecessary) hassle, but you're safe.
From Pub 970 (page 60: To determine if total distributions for the year are more or less than the amount of qualified education expenses, you must compare the total of all QTP distributions for the tax year to the adjusted qualified education expenses.
See previous discussions:
rollover within 60 days
Thanks - seems like its recommended to do a rollover to put the funds back into the 529 (since it has been < 60 days) and then an immediate withdrawl is the solution. I wonder if the 529 provider (Vanguard) will issue me a revised 2023 1099Q ?
I was questioning whether or not I would really have to do this rollover considering the IRS pub that says: "You must pay the qualified education expenses for an academic period that starts during the tax year or the first three months of the next tax year. " So, my qualified expense is from December 2023 and I AM paying it within 3 months, so I would think this would be ok despite crossing tax years? But, perhaps better on the safe side and do the rollover/withdrawl.
Q. I wonder if the 529 provider (Vanguard) will issue me a revised 2023 1099Q ?
A. No. But, you don't need it. You report it as a rollover (if you even report it).
Q. I was questioning whether or not I would really have to do this rollover considering the IRS pub that says: "You must pay the qualified education expenses for an academic period that starts during the tax year or the first three months of the next tax year. "
A. That only means you can pay for the first term of 2024 in Dec. 2023. But, it's questionable if you actually did that (posted 1/2/24).
Q. So I would think this would be ok despite crossing tax years?
A. I agree. It's just that there's no firm evidence of how the IRS might handle it. I think it's a common enough and reasonable situation that they will probably allow it.
Q. But, perhaps better on the safe side and do the rollover/withdrawal?
A. Yes. You have that option. Most of the time that we see this question, the taxpayer has already missed the 60 day window. It might be a minor (and unnecessary) hassle, but you're safe.
Thanks! Just one more question. If I do the rollover next week, do I report this against 2023? For instance, if my 2023 withdrawl was $30K but I rollover $15K "back" to 2023 next week, do I report my distribution as $15K for 2023? Just wondering how I would enter in Turbotax.....
Q. If I do the rollover next week, do I report this against 2023?
A. Yes. This is a case where the year doesn't matter, only the 60 days.
Q. If my 2023 withdrawal was $30K but I rollover $15K "back" to 2023 next week, do I report my distribution as $15K for 2023?
A. Yes, if that's what you decide to do. As previously discussed, it's probably safe to allocate the other $15K to first term 2024 expenses.
Q. Just wondering how I would enter in Turbotax?
A. It's best to just not enter the 1099-Q.
You can just not report the 1099-Q, at all, if your student-beneficiary has sufficient educational expenses, (including rollover amounts) to cover the distribution. When the box 1 amount on form 1099-Q is fully covered by expenses, TurboTax will enter nothing about the 1099-Q on the actual tax forms (nothing is sent to the IRS). But, it will prepare a 1099-Q worksheet for your records. You would still have to do the math to see if there were enough expenses left over for you to claim the tuition credit.
References:
If you do enter the 1099-Q, the interview will ask about rollovers. That will balance that amount out. Later, at the educational expenses (1098-T) section, you will enter the offsetting expenses. It can get confusing and mistakes are easily made. It's best to not enter the 1099-Q.
For more on 529 distributions, read on
____________________________________________________________________________________________
Qualified Tuition Plans (QTP 529 Plans) Distributions
General Discussion
It’s complicated.
For 529 plans, there is an “owner” (usually the parent), and a “beneficiary” (usually the student dependent). The "recipient" of the distribution can be either the owner or the beneficiary depending on who the money was sent to. When the money goes directly from the Qualified Tuition Plan (QTP) to the school, the student is the "recipient". The distribution will be reported on IRS form 1099-Q.
The 1099-Q gets reported on the recipient's return.** The recipient's name & SS# will be on the 1099-Q.
Even though the 1099-Q is going on the student's return, the 1098-T should go on the parent's return, so you can claim the education credit. You can do this because he is your dependent.
You can and should claim the tuition credit before claiming the 529 plan earnings exclusion. The American Opportunity Credit (AOC or AOTC) is 100% of the first $2000 of tuition and 25% of the next $2000 ($2500 maximum credit). The educational expenses he claims for the 1099-Q should be reduced by the amount of educational expenses you claim for the credit.
But be aware, you can not double dip. You cannot count the same tuition money, for the tuition credit, that gets him an exclusion from the taxability of the earnings (interest) on the 529 plan. Since the credit is more generous; use as much of the tuition as is needed for the credit and the rest for the interest exclusion. Another special rule allows you to claim the tuition credit even though it was "his" money that paid the tuition.
In addition, there is another rule that says the 10% penalty is waived if he was unable to cover the 529 plan withdrawal with educational expenses either because he got scholarships or the expenses were used (by him or the parents) to claim the credits. He'll have to pay tax on the earnings, at his lower tax rate (subject to the “kiddie tax”), but not the penalty.
Total qualified expenses (including room & board) less amounts paid by scholarship less amounts used to claim the Tuition credit equals the amount you can use to claim the earnings exclusion on the 1099-Q.
Example:
$10,000 in educational expenses(including room & board)
-$3000 paid by tax free scholarship***
-$4000 used to claim the American Opportunity credit
=$3000 Can be used against the 1099-Q (on the recipient’s return)
Box 1 of the 1099-Q is $5000
Box 2 is $2800
3000/5000=60% of the earnings are tax free; 40% are taxable
40% x 2800= $1120
There is $1120 of taxable income (on the recipient’s return)
**Alternatively; you can just not report the 1099-Q, at all, if your student-beneficiary has sufficient educational expenses, including room & board (even if he lives at home) to cover the distribution. You would still have to do the math to see if there were enough expenses left over for you to claim the tuition credit. Again, you cannot double dip! When the box 1 amount on form 1099-Q is fully covered by expenses, TurboTax will enter nothing about the 1099-Q on the actual tax forms. But, it will prepare a 1099-Q worksheet for your records, in case of an IRS inquiry.
On form 1099-Q, instructions to the recipient reads: "Nontaxable distributions from CESAs and QTPs are not required to be reported on your income tax return. You must determine the taxability of any distribution."
***Another alternative is have the student report some of his scholarship as taxable income, to free up some expenses for the 1099-Q and/or tuition credit. Most people come out better having the scholarship taxable before the 529 earnings.
Ok - so I called Vanguard today and they told me I don't need to do anything because the qualified expenses were INCURRED in 2023 despite being paid in 2024. The rep was seemed to feel very strongly that this is a straightforward situation and nothing would need to be done. Most of the websites out there tend to agree with the advice of trying to pay the college the same year as the withdrawl. For instance
https://www.savingforcollege.com/article/avoid-these-529-withdrawal-traps
#3 states: "Although you will not find this rule explicitly stated anywhere in the IRS’ publications or tax forms, the withdrawals from your 529 account must match the payment of qualifying expenses in the same tax year, regardless of academic year. If you withdraw the 529 money in December for a tuition bill that isn’t paid until January, you risk not having enough qualified education expenses during the year of the 529 withdrawal. Likewise, if you take a distribution in January to pay for expenses from the previous December, that distribution will be non-qualified." The Vanguard rep's information tis not aligned to this.
What's making me question the rep is she said one could not return money to a 529 within 60 days!
The advice is consult a tax professional!
Q. I called Vanguard today and they told me I don't need to do anything because the qualified expenses were INCURRED in 2023 despite being paid in 2024. The rep was seemed to feel very strongly that this is a straightforward situation and nothing would need to be done. Do you agree?
A. Yes. I think you're on firm ground and would not worry about it any more (although it's not that "straightforward"). In particular, you sent the payment in December.
Q. The Vanguard said one could not return money to a 529 within 60 days! Is that right?
A. No. But, we're seeing a lot of that, in this forum (it's not just vanguard). They appear to not want to make the effort. "Good help's hard to find".
First, appreciate all the e-mail responses as well as the speed!
Just for clarification, I made the college payment in 2024 and the 529 withdrawl in 2023 (which was against a 2023 bill for the 2024 spring semester). I only say that because you mentioned I made payment in 2023, which I want to clarify was 2024.
I took "the funds to the college did not post until 1/2/2024" to mean you tried to pay it in 2023.
I still think you're on firm ground.
Still have questions?
Questions are answered within a few hours on average.
Post a Question*Must create login to post
Ask questions and learn more about your taxes and finances.
Megnrust
New Member
cnhowardcell
Returning Member
Raph
Community Manager
in Events
seandallas
New Member
x9redhill
Level 2