Is a Contribution To a Puerto Rican CODA Plan Considered Untaxed Income?

Award Year: 2024-25 KA-36705 Helpfulness Rating 66 page views

This guidance is specific to the 2024-25 award year and later. For 2023-24* award year guidance see AskRegs Q&A, Is a Contribution To a Puerto Rican CODA Plan Considered Untaxed Income?

Scenario: There is an amount listed in box 15 of the Puerto Rico Form 499R2/W2PR (Withholding Statement), which is the equivalent of the U.S. Form W-2.

Answer: No. As a cash or deferred arrangement (CODA) plan, it is a contribution to a tax-deferred pension (similar to what is reported for codes D, E, F, G, H, and S in Box 12 of IRS Form W-2). Starting with the 2024-25 award year under the FAFSA Simplification Act, untaxed payments to tax-deferred pension and retirement saving plans are not reported on the FAFSA, are not included in need analysis, and are not other financial assistance (OFA) when packaging the student with Title IV aid.

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