Treasurer Compliance Calendar Washington and Lee University Annual Calendar of Significant Reporting Compliance Activities


Higher Education Act disclosure of Foreign Gifts/Contracts1

Tuition Payment Credit Reporting Requirements2

Tuition Payment Credit Reporting Requirements2

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Higher Education Act Disclosure of Foreign Gifts/Contracts1

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Equity in Athletics Disclosure Act3

Internal Revenue Code: Filing Form 9904

Tuition Payment Credit Reporting Requirements5

1Higher Education Act of 1965 and Higher Education Amendments of 1998
(Disclosure Requirements on Foreign Source Interests)
By January and July 31 of each year, a postsecondary institution must file a disclosure report about ownership or control by, or contracts with or gifts from foreign sources. The institution must make the disclosure by January 31 for the prior year July 1 to December 31, and by July 31 for the immediately preceding Jan. 1 to June 30 period.,br]
Gifts and contracts of $250,000 or more (individual or in combination with other gifts from and/or contracts with the same foreign source) received or contracted within a calendar year must be reported to the Department of Education. This report must also be made available to the public during regular business hours (20 U.S.C. §1011f(e)). This disclosure report should contain the dollar amount of gifts received from and/or contracts entered into with a foreign source other than a foreign government, the amount of gifts received from or contracts entered into with a foreign government, and if the U.S. institution is owned or controlled by a foreign source, the identity of the foreign source, the date the foreign source gained ownership or control, and institutional program or structural changes that took place as a result of the change in ownership or control.

If a restricted or conditional gift and/or contract is received by an institution, the following must also be disclosed: 1) the amount, date, and description of the conditions and restrictions for gifts received from and/or contracts entered into with a foreign source (other than a foreign government) as well as country of citizenship and country of incorporation; and 2) the amount, date, description of conditions and restrictions, name of foreign governments for gifts received from and/or contracts entered into with a foreign government.

A "foreign source" is defined as: 1) a foreign government, or agency of a foreign government; 2) a legal entity, governmental or otherwise, created solely under the laws of a foreign state or states; 3) an individual who is not a citizen or national of the United States or a trust territory or protectorate thereof; and/or 4) an agent, including a subsidiary or affiliate of a foreign legal entity, acting on behalf of a foreign source.

2Tuition Payment Credit Reporting Requirements
An institution or insurer must furnish a statement to each individual for whom it is required to file a Form 1098-T, on or before January 31 of the year following the calendar year in which payments were received, or amounts were billed, for qualified tuition and related expenses, or reimbursements, refunds, or reductions of such amounts were made.

3Equity in Athletics Disclosure Act of 1994
Each coed institution of higher education that participates in Title IV programs, and has an intercollegiate athletic program, must no later than Oct. 15th of each year, make available on request to enrolled students, prospective students, and the public, the report required to be produced under this law. If the report is available online, the school must also provide notice, either through mail, e-mail, or campus mail, giving the specific web site address where the request can be viewed and including a statement that a paper copy is available upon request. Within 15 days of making the report available to students, prospective students, and the public, (so at the latest Oct. 30th of each year) the school must submit the report to the Secretary of Education. This is done online at

4Internal Revenue Code: Filing Form 990
Exempt organizations who do not fall under a statutory exception must file an annual return with the Internal Revenue Service. The return must be filed on or before the 15th day of the fifth calendar month following the close of the institution's fiscal year. As the fiscal year at W&L ends on June 30th, the return is due Nov. 15th of each year.

5 Internal Revenue Code: Tuition Payment Credit Reporting Requirements
If the institution does not have a record of the individual's correct TIN, then it must solicit the TIN on or before December 31.