having fun with taxes part i new york state financial aid ... - tax w… · 1. agi (adjusted gross...

Having Fun with Taxes –Part INew York State Financial Aid Administrators Association (NYSFAAA)2020 –2021 Academic Year EditionRobert Weinerman, Director of Training

Iron Bridge Resources, LLC

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Disclaimer and Distribution▪ This PowerPoint slide deck is part of a presentation and is not

designed to be used as a stand-alone study document. The information cited in this presentation is based on▪ IRS publications, forms, and form instructions for 2018

▪ The most recent versions of each Department of Education publication▪ The most recent draft of the PDF FAFSA (June 24, 2019)

▪ Completing the FAFSA, 2019-2020

▪ The ISIR Guide and SAR Comment Codes and Text, 2020-2021

▪ Application and Verification Guide, 2019-2020

▪ The Program Integrity Website and announcements including all updates through September 16, 2019

▪ This presentation has been prepared for the New York State Financial Aid Administrators Association (NYSFAAA) membership. Distribution of this document to non-members is prohibited.

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Today’s Webinar September 23rd Webinar

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Agendas

▪ 2020-2021 Key Concepts

▪ Verifying Tax Filers

▪ Verification Requirements

▪ The 2018 Form 1040 and the 2020-2021 FAFSA

▪ Schedule 1 and the Simplified Formula/Automatic Zero EFC

▪ Rollovers

▪ Verification Documentation for Non-Filers

▪ Verifying Non-filers

▪ Who is Required to File a Tax Return?

▪ What is the Correct Filing Status for a Person?

Key 2020-2021 Concepts

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2019-2021 Verification Groups

https://ifap.ed.gov/dpcletters/GEN1902.html

5

Tax Filers Non-filers

V5

Agg

rega

te G

rou

p

V1

Stan

dar

d G

rou

p

▪ Adjusted Gross Income▪ U.S. Income Tax Paid▪ Untaxed Portions of IRA Distributions

and Pensions▪ IRA Deductions and Payments to Pensions▪ Tax Exempt Interest Income▪ Education Tax Credits

▪ Income Earned from Work

▪ Number of Household Members▪ Number in College

V4

Cu

sto

m

Gro

up

▪ High School Completion Status▪ Identity/Statement of Educational Purpose

IRA and Pension Distributions have been combined on the 2018 Form 1040


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GEN-19-02 attachment: https://ifap.ed.gov/fregisters/attachments/FR052419.pdf

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Auto Zero EFC Eligible Students▪ Dependent Students (V1)

▪ a

▪ Independent Students (V1)

▪ a

▪ V4 – HS Completion, Identity, and SEP

▪ V5 – All of the above

Parents are Filers Parents are Nontax Filers

AGI Income Earned from Work

Student/Spouse are Filers

Student/Spouse are Nontax Filers

AGI Income Earned from Work

Number of household members to ensure the independent student has at least one dependent other than their spouse

https://ifap.ed.gov/fregisters/attachments/FR052419.pdf

Tax Filers andVerification Requirements

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▪ Signatures and Currencies (Footnote 1)

Verification Documents - Filers

8


NEW

The copy of the 2018 income tax return must include the signature of the tax filer, or one of the filers of a joint income tax return, or the signed, stamped, typed, or printed name and address of the preparer of the income tax return and the preparer’s Social Security Number, Employer Identification Number, or Preparer Tax Identification Number.

DR

TTR

T


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Tax Return Signature Requirements

▪ If the taxpayer signed the tax return you may accept▪ A “wet signature” or a copied signature

▪ A joint tax return which has only one of the tax filer’s signatures on it

▪ An electronic signature that complies with the Electronic Signatures in Global and National Commerce (ESIGN) Act▪ See the Application and Verification Guide, 2019-2020, page 83

▪ If the taxpayer did not sign the return you may accept▪ The preparer’s name and Preparer Tax Identification Number (PTIN)

or

▪ The preparer’s name and SSN or EIN▪ Which has been signed, stamped, typed or printed with his name and address

▪ Do not accept a signature on Form 8879, IRS e-file Signature Authorization

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Tax Return Signature Guidance

Application and Verification Guide, 2019-2020, pages 81 and 83

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Victims of Tax-related Identity Theft

▪ A signed statement indicating that

▪ The taxpayer was a victim of IRS tax-related identity theft and

▪ The IRS has been made aware of the tax-related identity theft

▪ A Tax Return DataBase View transcript obtained from the IRS

▪ You may accept a TRDBV without any IRS markers or validation

Note: You must require the taxpayer to attempt to obtain the TRDBV

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Victims of Tax-related Identity Theft▪ No IRS

validation is required on the TRDBV if you have no reason to doubt its authenticity

▪ You must require the taxpayer to attempt to obtain a TRDBV before accepting a tax return

Ne

w a

nd

imp

ort

ant!

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Verifying by IRS DRT▪ The tax related verification items can be considered verified if the

FAFSA filer used the IRS Data Retrieval Tool and

▪ is not subsequently determined to have been incorrectly allowed to use the IRS DRT (IRS Request Flag 06)

▪ does not indicate that the taxpayer amended or the IRS changed the tax return after it was initially filed (IRS Request Flag 07)

▪ Unless

▪ you have reason to believe the taxpayer filed an amended tax return (which may not have been processed in time to be flagged during the IRS DRT process)OR

▪ you have received a tax return transcript and the “per computer” value is different from the data imported via the IRS DRT

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The New Form 1040 – Page 1

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▪ Forms 1040A and 1040EZ have been eliminated

▪ Six new schedules have been introduced

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The New Form 1040 – Page 2

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▪ Data that did not fit on the new Form 1040 is now on six new schedules

▪ Verification data appears on ▪ Form 1040

▪ Schedule 1

▪ Schedule 2

▪ Schedule 3

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Six New Numbered Schedules▪ Schedule 1 – Additional Income and Adjustments to Income

▪ All income that was not retained on Schedule A

▪ Line 12 – Schedule C business income

▪ Line 13 – Capital gains and losses

▪ Line 17 – Rental property, Partnerships, S corporations

▪ All adjustments to income

▪ Line 25 – HSA deduction

▪ Line 32 – IRA deduction

▪ Schedule 2 – Tax ▪ Line 46 – Excess Advance Premium Tax Credit Repayment

▪ Schedule 3 – Nonrefundable Credits▪ Line 50 – Education Credits

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Observation –Line numbers on Schedules 1 through 5 are the same as they were on the 2017 Form 1040

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Schedule 1 to Form 1040 – On-form▪ Line 22 from

Schedule 1 appears on Form 1040 on line 6, to the left of the total income

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Schedule 1 to Form 1040 – Off-form▪ Line 36 from

Schedule 1 does not appear on Form 1040 but reduces the AGI off-form

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If thesefigures are

different, checkSchedule 1 for

untaxed income (the IRA deductions and payments to self-employed plans)

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What if You Don’t Get a Schedule?

Application and Verification Guide, 2019-2020, page 83

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▪ This is just like what you did when you had a 1040EZ last year

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If you see this on the 2018 Form 1040 You need to review this Schedule

There is a number onSchedule 1

The box on line 11b is checked Schedule 2

The box on line 12 is checked Schedule 3 (Most likely line 50, AOC)


There is a number on line 6, Schedule 1

The box on line 11b is checked Schedule 2 (Most likely line 46, EAPTCR)


There is a number on line 6, next to “22” OR Line 6 and line 7 are different

Schedule 1

When Do You Need Schedules?

20

1,600

38,20032 65

14,512Rollover

39,86533,86512,000

21,865

2,635xx 2,000500

635

∆

2018 Form 1040 → 2020-2021 FAFSA

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Verification Data Items

GEN-19-02 https://ifap.ed.gov/dpcletters/GEN1902.html

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Verification Data Elements2017 (all from Form 1040) 2018 Tax Form

Adjusted Gross Income (AGI)

Line 37 Form 1040, line 7

US Income Tax Paid Line 56 minus Line 46Form 1040, line 13 minus Schedule 2, line 46

Untaxed Portions of IRA Distributions

Line 15a minus line 15bExclude Rollovers Form 1040,

Line 4a minus line 4bExclude RolloversUntaxed Portions of

PensionsLine 16a minus line 16bExclude Rollovers

IRA Deductions and Payments

Line 28 plus line 32Schedule 1, Line 28 plus Schedule 1, line 32

Tax Exempt Interest Line 8b Form 1040, line 2a

Education Credits Line 50 Schedule 3, line 50

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The Case▪ You are looking at the tax returns of a student you admitted to the

class of 2020-2021

▪ This student’s parent is a head of household with two children

▪ Your student, who was 17 at the end of 2018

▪ Your student’s sibling, who was 14 at the end of 2018

▪ Your student’s parent’s tax return reflects the following information in 2018

▪ They earned $50,000 in wages

▪ They collected $10,000 in unemployment compensation

▪ They contributed $5,500 to a traditional (deductible) IRA

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Form 1040 – Page 2 – Verification

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1. AGI (Adjusted Gross Income)

2. Income Tax after Credits(2017 Form 1040 line 56)

3. Tax-exempt Interest▪ Note it’s 2a. Last

year it was 8b

4. IRA and Pension Distribution▪ Line 4a – Line 4b

1

2

3

4

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Form 1040 – IRA/Pension Distributions▪ 2017’s lines 15

and 16 have been combined into 2018’s line 4

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What Schedules Do You Need?

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▪ Schedule 1

▪ Yes!

▪ Schedule 2

▪ No!

▪ Schedule 3

▪ No!

∆

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Schedule 1 – Verification5. IRA deductions

and payments to self-employed plans(lines 28 + 32)

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Schedules 2 and 3 – Verification6. Excess Advance

Premium Tax Credit Repayment (2017 Form 1040 – line 46)

7. Relevant Education Credit(2017 Form 1040 – line 50)

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6

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Form 1040 & Schedule 1 – Work▪ Earned

Income is Derived from ▪ Form 1040,

line 1

▪ Schedule 1, lines 12 & 18

▪ Schedule K-1 (Form 1065), Box 14, Code A(which will be zero if line 17 is blank)

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Schedule 1 – HSA Contribution

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▪ The Health Savings Account deduction is mentioned in FAFSA Q44h and Q92h and is untaxed income

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Schedules 4, 5, and 6 – No FAFSA Items

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2018 TRTs – Income Section

▪ Tax exempt interest income▪ IRA and Pension distributions have

not been combined on the transcript▪ Wherever the data are, just subtract

the taxable amount from the total amount

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2018 TRTs – Adjustments Section▪ IRA deductions and

payments to pensions(add together)

▪ Health Savings Account deduction(add together)

▪ Adjusted Gross Income (AGI)

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2018 TRTs – Tax and Credits Section

▪ Excess Advance Premium Tax Credit Repayment▪ Schedule 2, line 46

▪ Education Credits▪ Make sure you are in the Tax and Credits section

▪ Take the figure in the middle of the three lines

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2018 TRTs – Tax and Credits Section

▪ Income Tax after Credits

▪ Form 1040, line 13

▪ This figure is the last figure in the Tax and Credits section, just above the Other Taxes section

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2018 TRTs – New Fields

▪ Most of the new fields from the new Form 1040 appear in the middle of the Income section

▪ The value of the standard deduction is now reported on the transcript

▪ The old “Child Tax Credit” line has been replaced by a new “Child and Other Dependent Credit” line

▪ Other minor changes or additions

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2018 TRTs – New Fields

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1

1

2

2

3

3

4

45

5

is not the Education Credit you are looking for –you need the nonrefundable credit

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Comparing the 2017 and 2018Tax Forms

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The name of the Non-dependent Qualifying Person for HoH or the spouse of a taxpayer filing as MFS goes here

2017 vs. 2018 Filing Status Fields▪ Placement of

filing statusoptions has changed

40

MFS SpouseHoH nD-QP

MFS SpouseHoH Qualifying non-Dependent

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2017 vs. 2018 Claimed-by-Others

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▪ New position for “Someone canclaim you as a dependent” box

▪ Less relevant in2018 as the dependentexemption is worth $0

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2017 vs. 2018 Dependent Fields

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▪ If you need the number of exemptions, you must count it yourself

▪ Don’t forget to add one or two for the taxpayer(s)

Eligible for Expanded

Child Credits

Eligible for New Credit for Other

Dependents

Eligible for Child Credits

which must be imputed from the filing status

▪ Number of exemptions is no longer reported on the 2018 Form 1040

Auto Zero EFC and Simplified Formula2018 Form 1040 – 2020-2021

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Qualification RulesSimplifiedFormula

Automatic Zero EFC*

Income Earned from Work (non-filers) Adjusted Gross Income (filers)

Less than $50,000

Less than $26,001

The dependent student’s parents or the independent student and their spouse meet one of these three criteria:• They did not report certain income or adjustment items on a 2018 Schedule 1• One of them is a dislocated worker as defined in the Workforce Innovation and

Opportunity Act• Anyone counted in their household size received a means-tested federal benefit at

any time during 2018 or 2019, and the aid officer may use professional judgment if individual did not receive these benefits in these years, but is receiving them “now”

Application and Verification Guide, 2019-2020, pages 37 - 38

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*Independent students without a dependent other than a spouse do not qualify for the Automatic Zero EFC

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FIXX

DRAFT Simplified Formula Questions

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▪ The second draft of the 2020-2021 FAFSA shows the Department’s approach to the requirements to qualify for the simplified formulas

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DoE’s Approach▪ Students may qualify for the simplified formulas if they (and their

spouse) or their parents (if they are dependent students)

▪ Did not file a Schedule 1 or

▪ Filed a Schedule 1 that contains only these income/adjustment items

*At the time this program was produced, the Department’s FAFSA question was not finalized and suggested that any data inline 13 would be acceptable. Please review the guidance before implementing anything related to Schedule 1, line 13.

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Capital Gains Line 13, but not if the figure is negative (net capital gains are OK; net capital losses are not)

Unemployment Compensation Line 19

Alaska Permanent Fund Line 21, only if the income is $1,600 or $3,200 (joint only) with words “Alaska Fund” or similar

Educator Expenses Line 23

IRA Deduction Line 32

Student Loan Interest Deduction Line 33

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Schedule 1 – Simplified Formulas

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12,000

1,600Alaska Fund

13,674250

7,0002,500

▪ Capital Gains (if the figure on line 13 is not negative)

▪ Unemployment Compensation

▪ Alaska Permanent Fund (if a multiple of $1,600 and “Alaska” is written on line 21 or in a statement)

▪ Educator Expenses

▪ IRA Deduction

▪ Student Loan Interest Deduction

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9,750

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Schedule 1 – Not Eligible

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7,250See Statement

7,176

7,000

▪ Capital Loss (since the line 13 figure is below zero (a loss))

▪ Line 21(the 2018 Alaska Permanent Fund Dividend was $1,600. This figure must include other income that disqualified the student from the simplified formulas)

▪ This is a business retirement account

(74)

7,000

Rollovers

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IRA and Pension Distributions▪ Taxpayers are required to report almost all distributions from their

IRAs, Pensions, Retirement Plans, and Annuities in line 4a

▪ Some of these may be tax-free

▪ The untaxed portion is Form 1040, line 4a minus Form 1040, line 4b

▪ The FAFSA collects the untaxed portion of the distribution and includes it in the FAFSA Total Income (TI)

▪ But rollovers – transfers between retirement accounts, are excluded

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Total Distribution Taxable Amount

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FAFSA Questions 44e and 92e▪ Taxpayers indicate that at least a portion of their distribution (line

4a) by writing the word “Rollover” on line 4a

▪ If the word “Rollover” is not written on line 4a, the distribution should be included in FAFSA Question 44e or 92e

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FAFSA Questions 44e and 92e▪ Applicant does not use the IRS Data Retrieval Tool

▪ The applicant is expected to correctly report the untaxed portion of the distribution(s) by excluding the rollover

▪ Applicant uses the IRS DRT

▪ After the data has been retrieved from the IRS, if the difference between lines 4a and 4b is greater than zero, the applicant will be asked if the difference is due to a rollover

▪ If they answer “No”, the whole difference between lines 4a and 4b will be entered as the answer to FAFSA Q44e or 92e

▪ If they answer “Yes”, they will be asked to report the size of the rollover. The tool will subtract the applicant’s answer from the difference between line 44e and 92e, and that figure will be entered as the answer to FAFSA Q44e or 92e

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Rollovers and the IRS DRT

The ISIR Guide, 2020-2021, page 31

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https://ifap.ed.gov/eannouncements/080717ChangestoIRSDRT1819FAFSAForm.html

▪ The IRS Data Field Flag for the IRA/Pension Distribution question will be set to “2”

https://ifap.ed.gov/eannouncements/080717ChangestoIRSDRT1819FAFSAForm.html

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▪ The DRT will bring in $22,500 ($32,500 – $10,000) for Q44e or Q92e

▪ Because these values are non-zero, the IRS DRT will ask the taxpayer if they included any rollovers

▪ If they answer yes, they will be asked to report the rollover amount

▪ If they report $22,500, Q44e or 92e will fill with a $0 ($22,500 – $22,500)and the IRS Data Field Flag for this FAFSA item will be set to 2

▪ If they report $10,000, Q44e or 92e will fill with $12,500 ($22,500 – $10,000) and the IRS Data Field Flag for this FAFSA item will be set to 2

▪ If they answer no, Q44e or 92e will fill with $22,500

▪ and the IRS Data Field Flag for this FAFSA item will be set to 1

Rollovers and the DRT

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Verifying Rollovers▪ If the applicant used the IRS Data Retrieval Tool

▪ Get a signed confirmation that the IRA or pension distribution included a rollover

▪ If the applicant did not use the IRS DRT

▪ Get a signed statement with the rollover amount or a notation by the filer on the tax transcript that includes the word “rollover” beside any applicable item, similar to the instruction the IRS gives for Forms 1040 and 1040A

▪ The annotation must be signed and dated by the filer

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Verifying Rollovers

▪ Be careful: If you accept a tax return that has the tax preparer’s name and PTIN instead of the taxpayer’s signature, the document is not “signed and dated by the filer”


56D

RT

TRT

or

Tax

Ret

urn

Verifying Non-filers –Documentation

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Non-filers – Required Documents


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▪ A signed statement and some supporting documents

▪ Waiver authorization language (Footnote 4)

Sign

ed

Stat

eme

nt

W-2

VN

F Le

tter

o

r W

aive

r


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Guidance on Waiving the VNF Letter

https://ifap.ed.gov/eannouncements/010919Chngsto1819and1920VerificationReq.html

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New

▪ Two Partsto thestatement

▪ The non-filer tried to obtain a VNF from the tax authority

▪ AND they were unable to obtain it


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Waiving the VNF – Suggested Text▪ The Department had added this language into its Suggested

Verification Text document

▪ Based on this change, it appears that the waiver statement can be collected with the rest of the signed statement from the non-filer

▪ You do not need to have a two-step process

Suggested Verification Text, 2020-2021, pages 5 and 6

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VNF Waiver – AVG


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An

yon

e se

e th

e e

rro

r in

th

e b

old

tex

t fr

om

th

e A

pp

lica

tio

n a

nd

Ver

ific

ati

on

Gu

ide?

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Valid VNF Letters▪ U.S. based independent students and parents of dependent

students only

▪ Proof from the IRS that the taxpayer has not filed a tax return in 2018

▪ Dated on or after October 1, 2019

https://ifap.ed.gov/eannouncements/022317VerifciationIRSDocRequestsUsesMessaging.html

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Alternative Non-filer Documentation▪ Acceptable Non-filer Documents – Effective 02/2017

▪ IRS Verification of Nonfiling Letter

▪ Any IRS Form 13873 that clearly states that the form is provided to the individual as verification of nonfiling or that states that the IRS has no record of a tax return

▪ A Tax Return Transcript or a Tax Account Transcript that includes a message such as “no record of return filed” or “no transcript on file”

▪ Be careful here – if this document is requested after the taxpayer has filed their return but before the return is processed, these documents will return a “no record of return filed” response


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Documentation that Doesn’t Work


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▪ Review non-filer documents carefully and make sure they clearly state that the IRS does not have a record of a tax return on file for tax year 2018

Note: if you receive an unacceptable document, technically, you still need the student statement to include the “Attempted to obtain the VNF from the IRS or other tax authorities and was unable to obtain the required documentation” statement language.


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▪ From countries that provide non-filer verification

▪ their official document

▪ From countries that do not provide this documentation

▪ a signed statement

Non-U.S. Non-filers

https://www2.ed.gov/policy/highered/reg/hearulemaking/2009/verification.html

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Taxpayers with Valid Extensions▪ You may complete verification if you collect all the following from

a taxpayer with a valid post-October 15, 2019 filing extension

▪ A copy of the IRS’s approval of an extension beyond the automatic six-month extension for tax year 2018

▪ Verification of nonfiling from the IRS dated on or after October 1, 2019

▪ A copy of IRS Form W–2s for each source of 2018 employment income received or an equivalent document

▪ If self-employed, a signed statement certifying the amount of AGI and U.S. income tax paid for tax year 2018

▪ For 2020-2021, you do not need to collect an IRS Form 4868, Application for Automatic Extension of Time To File U.S. Individual Income Tax Return

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Taxpayers with Valid Extensions


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▪ Exception for certain servicepersons and individuals impacted by a national emergency (Footnote 3)

▪ Waiver authorization language (Footnote 4)Aga

in:

For

20

20

-20

21

, yo

u d

on

ot

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to

co

llect

IRS

Form

48

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Serviceperson/Disaster Exceptions▪ For active duty and qualifying National Guard servicepersons

who have not filed because of their service you must accept

▪ A statement from the individual stating that

▪ Because of their service, they have not filed a 2018 income tax return and

▪ Because of their service, they did not request a filing extension from the IRS

▪ A copy of each W–2 received for the specified year or, for a self-employed individual, a statement by the individual certifying the amount of AGI and U.S. income tax paid for the specified year

▪ For National Disasters, check if the IRS has issued a blanket extension for a region impacted by a natural disaster, which “counts” as an IRS approval letter

▪ See https://www.irs.gov/newsroom/tax-relief-in-disaster-situationsGEN-19-02 attachment: https://ifap.ed.gov/fregisters/attachments/FR052419.pdf

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https://www.irs.gov/newsroom/tax-relief-in-disaster-situations


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https://www.govinfo.gov/content/pkg/FR-2017-09-29/pdf/2017-20844.pdf

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“Affected Individuals” Relief Source

https://www.govinfo.gov/content/pkg/FR-2017-09-29/pdf/2017-20844.pdf

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Verification of a Non-filer w/o a TIN▪ If a non-filer does not have an SSN, ITIN, or EIN

▪ A signed and dated statement--

▪ Certifying that the individual(s) does not have a Social Security Number (SSN), an Individual Taxpayer Identification Number (ITIN), oran Employer Identification Number (EIN) and

▪ Listing the sources and amounts of earnings, other income, and resourcesthat supported the individual(s) for the appropriate tax year; and

▪ If applicable, a copy of IRS Form W–2 for each source of employment income received for the appropriate tax year or an equivalent document

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In Closing

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Useful Links▪ Federal Register – FAFSA Information To Be Verified for the 2020-

2021 Award Year

▪ https://ifap.ed.gov/fregisters/attachments/FR052419.pdf

▪ New Documentation Guidance (January 9, 2019)

▪ https://ifap.ed.gov/eannouncements/010919Chngsto1819and1920VerificationReq.html

▪ Completing the FAFSA – 2019-2020

▪ https://studentaid.ed.gov/sa/sites/default/files/2019-20-completing-fafsa.pdf

▪ IRS Transcript Information

▪ https://www.irs.gov/individuals/tax-return-transcript-types-and-ways-to-order-them

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https://studentaid.ed.gov/sa/sites/default/files/2019-20-completing-fafsa.pdf

https://www.irs.gov/individuals/tax-return-transcript-types-and-ways-to-order-them

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Useful Publications

Publication 3 Armed Forces’ Tax Guide

Publication 17 Your Federal Income Tax

Publications 590a and 590b

Contributions to and Distributions from Individual Retirement Arrangements (IRAs)

Publication 926 Household Employer’s Tax Guide

Publication 970 Tax Benefits for Education

Publication 4012Publication 4491

VITA/TCE Volunteer Resource GuideVITA/TCE Training Guide

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Today’s Webinar September 23rd Webinar

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Upcoming NYSFAAA Tax Training

▪ 2020-2021 Key Concepts

▪ Verifying Tax Filers

▪ Verification Requirements

▪ The 2018 Form 1040 and the 2020-2021 FAFSA

▪ Schedule 1 and the Simplified Formula/Automatic Zero EFC

▪ Rollovers

▪ Verification Documentation for Non-Filers

▪ Verifying Non-filers

▪ Who is Required to File a Tax Return?

▪ What is the Correct Filing Status for a Person?

Conference

▪ Overview of the New Tax Code

▪ Amended Tax Returns

Thank You!Robert Weinerman, Director of TrainingIron Bridge Resources, LLC

[email protected]

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