Tax Policies

The following topic list references Financial Affairs policies and Human Resources policies that address tax issues, which may impact employees, students and affiliates. Click on the topic for a brief summary and a link to the policy.

The University does not reimburse or allow for donations to be made on a procard. Donations to any political campaign or party affiliation are strictly prohibited from a University fund source. 

The Accountable Plan Expense Reimbursement Policy (FA 111) addresses the guidelines for making donations with University funds to external organizations.

Donations and sponsorship recipient payees must have a Georgetown Management System (GMS) Supplier ID (SUP-XXXXXXX).

Use GMS Spend Category S0264 for donations, and S0013 for sponsorships made to external organizations. Donations and sponsorships should be made to similarly missioned 501(c)(3) organizations.

Please contact University’s Tax Department before committing to making donations or sponsorships totaling over $5,000 in any fiscal year.

The purpose of the Accountable Plan Expense Reimbursement Policy (FA 111) is to establish the rules for the University’s accountable plan and outline the tax treatment of cash advances, expenses reimbursements and ProCard transactions.

The University does not reimburse or allow for donations to be made on a procard. Donations to any political campaign or party affiliation are strictly prohibited from a University fund source.  Please consult the Tax Department prior to making any external donations over $250. 

Reimbursements to students do not generally fall under the University’s Accountable Plan unless a faculty member will attest to one of the following scenarios as being true:
– The travel directly supports a faculty member’s project or research program
– The travel is related to presenting or leading a session at a conference on behalf of the University
– The travel is required to officially represent the University

If the primary beneficiary of the travel is the student, it most-likely should be treated as a non-service stipend. If the primary beneficiary of the travel is a faculty member or other employee for University business, it may be treated as an accountable plan business expense as long as the receipts are submitted within 60 days.

When calculating Per Diem Payments to Individuals on travel under the University’s Accountable Plan, this Per Diem Calculation Form may be helpful as backup for the substantiation required to meet the accountable plan rules.

Please note that the Tax Department is currently in the process of updating this policy to clarify that the 60 day window for ProCard transactions start from the Posted Date of the transaction, not the Transaction Date.

As outlined in the Employee Mobile Device Tax Compliance Policy (FA 129), a University-provided mobile device is considered to be part of an employee’s gross income unless it is used primarily for business purposes. Immaterial and incidental personal use is permitted. Prior to issuing a device to an employee, please read UISO’s University-Provided Mobile Device Policy as well.

The Tax and Reporting of Moving Expense for Employees Policy (HR 1014) addresses the tax treatment of Employee moving expenses. For tax years 2018 through 2025 are considered wages and will be reimbursed net of the required tax withholding.

The Tax Treatment of Athletic and Other Event Tickets Purchased with University Funds policy (HR 1015) addresses the tax implication of receiving tickets to athletic or other events purchased with University funds. The occasional Georgetown University athletic or other Georgetown University event tickets provided to an employee for personal use is excluded from the employee’s income. Regular use of athletic or other event tickets by an employee for non-business purposes will result in taxable income to the employee subject to applicable tax withholding.

The University offers an undergraduate and graduate level Tuition Assistance Program (TAP). The Tuition Remission Tax Liability for GU Employees Policy (FA 103) provides information on the taxation of tuition benefits.

The Gift Policy (FA 162) provides guidance to departments giving gifts to employees and non-employees, as well as guidance to employees receiving gifts from external parties in their role as a GU employee. Departments should have the applicable form completed, complete the Georgetown University Gift Form and maintain completed and signed forms in their University department. A copy of the applicable form should also be uploaded as a PDF with the online gift form submission:
1) FA 162-A Gift Receipt Form – To be completed by University employees receiving a gift from an individual or entity other than Georgetown University.
2) FA 162-B Award and Prize Form – To be completed by individuals (who are not employees) receiving prizes or awards outside of Accounts Payable or Nimblify.
3) FA-162-C Gift Policy Payroll Form – To be completed by University employees given a gift with University funds.

The Reporting Cash Transactions Policy (FA 181) outlines how the University complies with its IRS Form 8300 reporting requirement. When the University receives of any single cash payment or series of payments on a related transaction within a 12-month period that exceed $10,000 it must be reported to the IRS. In a University setting, the most frequent payment of this type would be tuition. A single tuition payment or a series of payments exceeding $10,000 must be reported.

Please note that the Tax Department is currently in the process of updating this policy to clarify that there is no requirement to report for cash transactions that occur outside the United States if the entire transaction consists of both: (1) the underlying event that gave rise to the transfer of cash and (2) the receipt of cash by the recipient. For example, if a student will attend classes at locations outside the U.S. and the cash tuition payments are made and received by campuses located outside the U.S., this policy does not apply.

Revenue Generating Agreements Policy (FA 157) provides guidance on which types of agreement are routed through this review process. The Tax Department reviews revenue generating agreements to determine if the activity generates unrelated business income and/or private business use.

Through the Student Employees – Applicability of FICA Tax (HR 1012) Georgetown University has automated procedures that complies with IRC Section 3121 (b) (10), which provides an exemption from FICA tax for service performed by a student employed by the university in which he/she is enrolled and regularly attends classes.

The Tax Treatment of Subsidized University Housing for Senior Administrators, Faculty, and Staff Policy (FA 169) addresses the tax implications of University provided housing, which is generally treated as income meaning that the subsidized portion of the housing is taxable to the employee who receives the benefit under the Internal Revenue Code. However, there are certain circumstances in which the value of the subsidized portion of the employer-provided housing is appropriately excludable from income.

The Tax Treatment and Reporting of University Provided Motor Vehicles Policy (FA 167) addresses the tax treatment of University vehicles by employees. Under the Internal Revenue Code, a motor vehicle provided to an employee by the University is considered a working condition fringe benefit and no portion of the value of the vehicle needs be included in the wages of the employee. However, if the vehicle is used for personal purposes, an allocation based on mileage will be used to determine the amount of personal use.

The purpose of the New Entities and Presence Policy (FA 623 formerly FA 177) and Procedure (includes map of approved teleworker states) is to identify and monitor financial, legal, employment, risk, and tax compliance components as the University (a) develops new entities (b) develops a new or expanded legal presence in US or non‐US jurisdictions, or (c) enters into international agreements.

This policy impacts where University departments are able to directly employ teleworker employees. Here is a list of the currently approved teleworker states outside of Washington D.C., Virginia, and Maryland: California, Florida, Illinois, Louisiana, Massachusetts, Minnesota, New Jersey, New York, North Carolina, Ohio, Tennessee, Texas, Pennsylvania, Washington state and West Virginia.

If you are considering hiring a teleworker employee and their state of residence is not listed as approved, please reach out to Human Resources to see if hiring through the University’s current Employer of Record Firm is an option.

The University’s Senior Leadership may consider adding states after legal and tax research is conducted if there is a strong business case. Please email taxdepartment@georgetown.edu to initiate this review process.