SUBJECT: IRS REPORTING REQUIREMENTS REGARDING RECEIPT OF NONCASH GIFTS AND RECEIPT OF CASH IN EXCESS OF $10,000
This APL summarizes three separate Internal Revenue Service (IRS) reporting requirements regarding certain gifts made to the University, identifies required procedures, and identifies areas of responsibility to ensure full compliance with federal regulations.
II. SUMMARY OF THE THREE AREAS REQUIRING REPORTING TO THE IRS
The IRS requires the University to complete the donee section of Form 8283, Noncash Charitable Contributions, to acknowledge certain noncash gifts if the form is presented to the University by the donor. Subsequently, the University must notify the IRS using Form 8282, Donee Information Return if the property received is disposed of within three years. (See also Form 8283 Instructions.)
In addition to Forms 8283 and 8282, the University is required to file Form 1098-C, Contributions of Motor Vehicles, Boats, and Airplanes with the IRS for each contribution of a qualified vehicle that has a claimed value of more than $500. (See also Form 1098-C Instructions.)
IRS regulations further require that the University file Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business for all receipts of cash, including gifts, in one or in two or more related transactions of more than $10,000. This form must be filed with the IRS within 15 days of receiving such payments. This requirement does not apply to checks or other negotiable instruments.
III. REPORTING REQUIREMENTS FOR NONCASH CONTRIBUTIONS
The IRS does not require the University to file Form 8283, Noncash Charitable Contributions nor is the University responsible for initiating the form to donors. However, the University is required to sign the form if requested to by the donor.
If the University is presented with Form 8283 by a donor and has received the property described in Part I of Section B, Donated Property Over $5,000 (Except Publicly Traded Securities), an authorized University official must complete Part IV, Donee Acknowledgment. The authorized University official is the campus Chief Business Officer (or designee). The original form must be returned to the donor and copies of the signed form are to be sent to the Facilities Office (if appropriate), the campus Development Office and the University Services Controller’s Office.
A signed donee acknowledgement represents receipt of the property described in Section B, Part I and on the date specified on the form. It does not represent concurrence in the appraised value of the contributed property. The signature also indicates knowledge of the information reporting requirements on dispositions, in accordance with Form 8282.
The University is required to report on Form 8282, Donee Information Return the sale, exchange, consumption, transfer or other disposition of noncash contributions for which the University signed, or was presented with for signature, Form 8283, Section B, Part I, Information on Donated Property, which exceeded $5,000, if the disposition occurs within three years of the receipt of the contribution.
The campus Chief Business Officer (or designee) is the authorized University official who is responsible for signing and submitting Form 8282 to the IRS within 125 days after the University disposes of the property. The original form is to be mailed to:
Department of the Treasury
Internal Revenue Service Center
Ogden, UT 84201-0027
Copies of Form 8282 are to be sent to the Facilities Office (if appropriate), the campus Development Office and the University Services Controller’s Office.
IV. REPORTING REQUIREMENTS FOR CONTRIBUTIONS OF QUALIFIED MOTOR VEHICLES, BOATS, AND AIRPLANES
Please note: Form 1098-C Contributions of Motor Vehicles, Boats and Airplanes is not available in fileable form online. Fileable forms are available at the University Services Controller’s Office.
The reporting requirements for tangible gifts of qualified motor vehicles, boats, and airplanes under section 170(f)(12) of the Internal Revenue Code are in addition to requirements for IRS Forms 8283 and 8282. A qualified vehicle is any motor vehicle manufactured primarily for use on public streets, roads, and highways; a boat; or an airplane.
For donations of qualified vehicles with a claimed value of more than $500, the Campus Chief Business Officer must provide “Copy B” and “Copy C” of Form 1098-C to the donor within 30 days of the gift or sale of the gift. The original “Copy A” of the Form must be sent to the University Services Controller’s Office at that time. The University Services Controller’s Office will file all individual 1098-C forms, which it receives throughout the calendar year, with the IRS by the end of February. Campuses are also required to send a photocopy of the form to the Facilities and Development Offices.
The University is required to certify its intended use of the vehicle on Form 1098-C. If the University intends to sell the donated property without a significant intervening use or material improvement, boxes 4a, 4b and 4c must be completed. If the University intends to use the vehicle for a significant amount of time, the University must certify that the donated vehicle will not be sold before completion of a significant intervening use or material improvement by the University by checking box 5a and completing box 5c.
V. REPORTING REQUIREMENTS FOR THE RECEIPT OF CASH
Any receipt of coin and currency in amounts exceeding $10,000 in one transaction or two or more related transactions within any 12-month period must be reported to the IRS on Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business. The term “Cash” includes U.S. and foreign coin and currency received in any transaction.
The campus Chief Business Officer (or designee) is the authorized University official who is responsible for signing and submitting Form 8300 to the IRS by the 15th day after receipt and must include the taxpayer identification number (TIN) and other personal information about the person from whom the University received the cash. The form should be sent to:
Internal Revenue Service
Detroit Computing Center
P.O. Box 32621 Detroit, MI 48232
The campus must forward a copy of the completed form to the University Services Controller’s Office. A copy of the form must be retained for five years after the filing date.
The University Services Controller’s Office will furnish each person named on Form 8300 with a written or electronic statement by January 31 of the year following the calendar year in which the report was filed. The statement must show the name, telephone number and address of the information contact for the business receiving the cash, the aggregate amount of reportable cash received during the year and must state that the information was reported to the IRS. See Exhibit A for a sample statement.
Forms and Related Documents
Form 8283 Noncash Charitable Contributions
Instructions for Form 8283 Noncash Charitable Contributions
Form 8282 Donee Information
Return Instructions for Form 1098-C
Form 8300 Report of Cash Payments over $10,000 Received In a Trade or Business
APL Section V-B – Gift Administration
Policy 706 Acceptance of Gifts, Development Activities and Fund Raising Campaigns
Approved by the Treasurer of the University of Maine System. Official copy on file in the Office of Finance and Administration.
Vice Chancellor for Finance and Administration
EXHIBIT A – SAMPLE CASH SUMMARY STATEMENT
January 1, 2017
University of Maine System
5703 Alumni Hall, Suite 101
Orono, ME 04469-5703
Ms. Jane Doe
94 Main Street
Bangor, ME 04401
Dear Ms. Doe:
Under Title 26 U.S. Code §6050I , the University of Maine System is required to report the receipt of more than $10,000 in cash in one transaction or two or more related transactions.
The following is a summary of the total cash that the University of Maine System received from you in such transactions during the calendar year 2016:
Enclosed for your reference are copies of the Form 8300 used to report these transactions to the Internal Revenue Service.
If you have any questions, please contact me.
Assistant Director of Accounting