In order to ensure compliance with current IRS policies, the University will begin withholding tax on Tuition Assistance Program (TAP) benefits for classes that meet all three of the following three criteria (1) If the classes are taken for graduate credit (courses taken for undergraduate credit or for no credit are not taxable); and (2) If classes do not meet the IRS standard of job-relatedness; and (3) If the total tuition benefit used for such courses during the calendar year exceeds $5,250 (only amounts over $5,250 are taxable).

How to Avoid Owing Tax on Your Classes: Make a Case for Job-Relatedness

You may be able to avoid owing tax on your class up front, if you use Harvard’s Graduate Credit TAP Form to make a short informal argument that your course is job-related in the “Job-Relatedness Attestation” section of the form.

• MAKING A CASE FOR JOB-RELATEDNESS:  In order for a course to be considered “job-related,” it does not need to be related to your core job duties, it just needs to be related to some aspect of your job.   For example, if you are a faculty assistant and you are taking a class in web design, that class may not related to your core duties. However, it may provide useful skills to help you maintain the website that you update regularly for one of your faculty members — and that is where  you could focus your job-relatedness argument on the form. Another example: if you are an executive education program coordinator and you are taking a writing course, this class is may not related to your core duties, but it may assist you in writing the monthly newsletter updates on program alumni that you sometimes contribute to the department newsletter. If you are in a degree program, you should consider how the job-relatedness standard applies to each individual course. For example, if you are doing a degree in psychology, you may not be able to make the case that every course you take for your program can help you in your current job, but you may be able to make a case that some of your courses could help you in your current job.If you are making a job-relatedness argument, you will want to check “yes” in the section of the Graduate Credit TAP Form that asks whether your course meets the IRS standard for job-relatedness. The job-relatedness argument you make on the form can be short and informal. You will be asked to enter your supervisor’s email address so that your supervisor can “sign off” electronically on your Job-Relatedness Attestation. Once you submit the form, a PDF of the form will be emailed to you from Benefit Strategies (no-reply@benstrat.com). If you have designated any courses as job related, a PDF will also be sent to your manager/supervisor with a link to the online approval form. Your supervisor’s approval must be received by the TAP form deadline listed on the form, so you may want to follow-up with them to be sure they sign by the deadline.
• UNABLE TO MAKE A CASE FOR JOB-RELATEDNESS:  If your course is not job-related (or if you are not able to get your supervisor’s signature on your TAP form), you can apply for 40% reimbursement of any tax you owe on Harvard courses for this semester (spring 2021) ONLY using the Transitional TAP Fund (TTF). You can find the TTF reimbursement form on Benefit Strategies website: https://www.benstrat.com/harvard/.  This the last semester that Harvard will be offering this reimbursement. You can learn more about how the Transitional TAP Fund works on the following page (click on the third blue bar). Even if your course is not job-related, you still need to fill out the TAP form, but under the section that asks whether your course meets the IRS standard for job-relatedness, you check “no.”

The HUCTW office will try to answer your questions about the new TAP tax changes as best we can, however please note that this new TAP tax withholding is a Harvard Benefits Office program (created, overseen, and enforced by the Harvard Benefits Office). So, if you would like definitive confirmation about deadlines, requirements, taxes-owed, etc, you should contact that Harvard Benefits Office (617-496-4001, benefits@harvard.edu) or the company they pay to process the TAP forms, Benefit Strategies.