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Potential Tax Implications for Tuition Refunds

With campuses closing due to the coronavirus pandemic, many colleges are refunding a prorated portion of tuition and/or room and board costs. However, if you used funds from a 529 plan to pay for those education expenses, the refunded amounts may warrant further consideration.

The tax snag: mismatched amounts

Refunded amounts that were originally paid out of a 529 plan could create a unique tax situation, as payments for tuition, housing, and fees that were once qualified may no longer be considered as such. When a refund is issued, the total amount taken from the 529 plan will likely no longer match the amount of qualified education expenses the student incurred for the year. This mismatch could cause the refunded amount to be considered a non-qualified expense when filing taxes – and it may result in a tax penalty.

The workaround: recontribute the refund

When refunds are issued from a qualified institution, families who used a 529 plan to pay for educational expenses have the option to recontribute the returned payment back into a 529 plan. Re-contributing the refunded amount will prevent that portion of the 529 distribution from being considered non-qualified and taxable.

  • The account holder has 60 days from the date of the refund to recontribute the funds. The original distribution date is irrelevant. In 2020, the IRS has extended the deadline so that the re-contribution may be made until July 15, 2020, even if the re-contribution date is more than 60 days from the refund date.
  • The owner can either send a personal payment or endorse the school’s check to the appropriate plan. The re-contribution will display as a 2020 contribution in the account.
  • The owner must keep proof of the refund for his or her records. 529 accounts do not report contributions on a tax form to the IRS the way IRAs do, therefore it is the account holder’s responsibility to provide the IRS with proof of the refund and the re-contribution. A tax advisor can provide guidance on filing taxes after re-contributing part of a distribution.

If you need help determining what can be done with 529 funds and how to avoid tax implications, please let me know!

Raymond James and its advisors do not offer tax or legal advice. You should discuss any tax or legal matters with the appropriate professional.