My daughter is a freshman in college so I am new to the world of 529 distributions.
In July 2021 I took a $20,019 distribution to pay for her first semester in the fall of 2021. In late December 2021 I took second distribution of $21,849 to pay for the spring 2022 semester, due on January 6, 2022. The 1099-Q I received from the 529 plan reflected the total of both distributions of $41,868.30, however the 1098-T I received from the school only reflects the first semester tuition of $23,019. From the standpoint of tax years there is now a mismatch of distributions vs espenses. How should this timing discrepancy be handled for tax purposes? If I cannot offset the spring semester expenses, according to the Turbo Tax program, it seems I have to pay taxes on the $21,849 since I took the distribution in 2021 for 2022 payments. Please advise.
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You can treat the payment made in 2021 for the spring semester as having occurred in 2021 even though it is not stated as such on the form 1098-T. When you enter the form 1098-T in TurboTax, you will see an option that says What if this is not what was paid to this school? under the Box 1 entry. Check that box and you can adjust the amount of education expenses reported on the form 1098-T.
Just don't enter the 1099-Q.
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."
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. So, there is no way to document your situation with your tax filing.
Technically, a 529 distribution must occur in the same year the expenses were paid. This problem, of mismatched year end distributions, is fairly common. Treat it as received in 2022 (I know this disagrees with the other reply - neither answer is right or wrong) and report it next year (you probably won't need to enter anything next year either). And hope you can explain it away if you receive an IRS notice (unlikely). You certainly meet the intent of the 529 rules, if not the strict letter. We haven't seen any reports, in this forum, of how that specific problem has actually worked out. But, this is the usual advice.
Do a better job on timing next year.
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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 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 (usually on the student’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
You have $1120 of taxable income
**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.
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