Our recent update to 1098-Ts included a number of checks and features to help you better comply with new IRS tax reporting guidelines. Chief among those was that students with blank or invalid Social Security Numbers could not have their 1098-T forms released in Populi for 2016. Additionally, these students' forms would not be included in any export (save for the unofficial XLS export).
However, after speaking with several customers, and having taken several more looks at the IRS regulations, we have determined that:
- The regulations are ambiguous enough that it just might be okay to issue a form without a TIN (SSN).*
- There are likely legitimate reasons to issue a 1098-T with a blank TIN (SSN).
- "Placeholder" SSNs (like 123-45-6789) are definitely forbidden. No two ways about that.
Accordingly, we have modifed the 1098-T report located under Financial > Financial Aid > Reporting > 1098-T to allow for the release of forms without an SSN. Placeholder SSN's will still prevent the release of a student's 1098-T; we have added additional checks to prevent these from being entered or imported in the future.
If you have already released your forms for this year, you will want to go back and review the list of students. You may choose to release and print some additional forms for students who were previously skipped.
If you have any additional questions, please contact Populi customer support.
* In the regulations shown here (pdf link), it appears that if the student doesn't provide a TIN, you should leave that space blank. It also says that if you leave that space blank, you'll probably be fined.