Section 529 Plans for Pennsylvania Residents

This Article will discuss 529 Plans and will focus on some of the estate planning advantages of these plans.  There are many, more detailed sources of information about these plans.  We have inserted some links to these other resources at the end of this Article. [See below.]

Please note - this article has not been updated since some recent changes to Pennsylvania's plans (November 2006).

How the Plans Work Generally

Section 529 Plans provide advantageous ways for people to save for college.  A person (the account owner) can establish a 529 Plan account with the sporsoring agency or company and the account owner can designate a beneficiary on the account.  After the account is established, the account owner makes contributions to the account for the beneficiary.  Generally, the beneficiary may be changed by the account owner with the approval of the sponsoring agency (in a Pennsylvania plan, with the approval of the Pennsylvania Treasury).  The replacement beneficiary must be a member of the family of the original beneficiary.  Eventually, the funds can be used for college tuition for the beneficiary.  

Tax and Other Advantages

There are various advantages to 529 Plans, some of them tax related.  First, the investment in the account grows free from income tax.  Second, when qualified distributions are made from certain plans and used toward the payment of qualified education expenses, the distributions are also income tax free.  Third, the account owner maintains control of the funds and always retains the right to make withdrawals at any time.  Fourth, there may be the opportunity to lock in tuition rates at certain colleges and universities at today's rates, as for example in certain Pennsylvania plans.  Fifth, Pennsylvania plans are protected from the claims of creditors.  There may be adverse income tax consequences and penalties for certain non-qualified withdrawals from the accounts.  The tax treatment of Pennsylvania 529 Plans for non-residents of Pennsylvania does not have all the advantages as for Pennsylvania residents.  

Contributions to a 529 Plan are treated as completed gifts to the beneficiary for Federal Gift Tax purposes.  Making gifts can be an excellent way for a person to save Federal Estate Tax.  (This Web Site contains a more detailed article on the topic of "Gifts.")  The basic principle is that if a person gives away money or property during his or her lifetime pursuant to an appropriate plan, the property will not be in that person's estate when he or she dies and therefore, the heirs will not have to pay Federal Estate Tax on that property.  Normally, if a person attempts to make a gift, but does not really give the property away (that is, if he or she retains control over the gifted property), the property will still be taxed in that person's estate when he or she dies.  529 Plans are a significant exception to that general rule.  When a contribution is made to a 529 Plan, it is treated as an asset that belongs to the designated beneficiary for Federal Estate Tax purposes, even though the account owner retains control over the funds.  Therefore, the account owner's taxable estate is reduced by the amount of the contributions made to the plan (up to certain maximum amounts), even though he or she still controls the funds.  This is a unique advantage to 529 Plans.

Because contributions to 529 Plans are treated as completed gifts for Federal Gift Tax purposes, there are potential Federal Gift Tax consequences that result from making these contributions.  Generally, gifts (including gifts to 529 Plans) are subject to Federal Gift Tax.  However, the law permits every person to make gifts each year to an unlimited number of people up to a certain dollar amount per person.  This amount is now $11,000 each year per person.  These gifts are known as "Annual Exclusion Gifts."   Therefore, an account owner can make gifts of up to $11,000 each year to a 529 Plan for any number of beneficiaries without incurring any Federal Gift Tax.  Normally, where a gift is made to a trust and the terms of the trust do not permit the recipient to immediately use or withdraw the gift, the gift is not even eligible as an Annual Exclusion Gift.  A gift to a 529 Plan, although the beneficiary may not be able to use or withdraw it immediately, is still eligible as an Annual Exclusion Gift.  This is another significant advantage to 529 Plans.

A married couple, for example, a set of grandparents, can double this annual amount through a process known as "gift splitting", even if all the funds come from only one of those persons.  By following the appropriate procedures, each spouse is treated as having made a separate $11,000 gift to the 529 Plan in a given year, permitting a total of $22,000 to be contributed annually to the 529 Plan for a beneficiary without paying any Federal Gift Tax.  There is also a method by which an account owner can contribute more than $11,000 (or $22,000 if splitting gifts) in a given year without adverse gift tax consequences, by pro-rating a gift over a five year period.  This means that an account owner may be able to make a one-time gift of up to $55,000 (or $110,000 if splitting gifts) for each beneficiary and treat this aggregate amount as if it had been made over a five year period.  This is another unique advantage of 529 Plans.  A properly prepared Federal Gift Tax Return must be filed to implement this strategy.  Additional contributions or the death of the person making the contribution within five years can have adverse gift and estate tax consequences.  It is important that a knowledgeable attorney or accountant be consulted before implementing a gifting plan, especially a plan involving more than an $11,000 contribution, to be certain that the contribution takes maximum advantage of the favorable provisions in the tax laws.  

529 Plans also have advantages over the more traditional custodial accounts (UGMA or UTMA accounts).  When a child reaches a certain age, the funds in a custodial account are no longer controlled by the custodian but belong to the child.  The child could decide to use the funds for something other than college.  The 529 Plan, in contrast, is always under the control of the account owner, without regard to the age of the beneficiary.

Pennsylvania Plans

Pennsylvania law specifically provides for Qualified State Tuition Programs, sometimes called Pennsylvania TAP 529 Plans.  Pennsylvania provides for two types of plans - the Guaranteed Savings Program Fund  (the "Guaranteed Fund") and the Investment Program Fund (the "Investment Fund").  The account owner can establish a Pennsylvania TAP 529 Plan account with the Pennsylvania Treasury by entering into a "Tuition Account Program Contract" (TAP Contract). 

The Guaranteed Fund comes with a guarantee - that the account will grow at the same rate that tuition increases at a beneficiary's chosen institution or tuition level.  Each contribution to the Guaranteed Fund is used to purchase tuition credits at the tuition level designated by the account owner in the TAP Contract.  When tuition rates increase, the value of the account increases at the same rate.  The Guaranteed Fund enables individuals to pay for higher education expenses at today's lower prices.  Many (but not all) public and private institutions of higher education participate in the Guaranteed Plan.  A potential account owner should investigate whether the chosen school participates before establishing an account.  

The Investment Fund gives an account owner flexibility in investment options but has no guarantee.  There is a risk that contributions will not rise at the same level as a school's tuition rates.  However, the account owner may also reap greater rewards in the Investment Fund because the account may grow faster than tuition rates.  The Investment Fund gives an account owner the option of taking a more aggressive investment approach or a more conservative investment approach based on his or her own risk tolerance level.

Pennsylvania residents are not limited to 529 Plans from the Pennsylvania Treasury.  Many other plans are also open to Pennsylvania residents.  A careful investigation should be made before selecting a particular 529 Plan because there are significant differences in fees and costs as well as differences in investment returns.  A Pennsylvania 529 Plan may not be the best choice even for a Pennsylvania resident.

Summary

Section 529 Plans may be an excellent way to save money today for the higher education expenses of tomorrow and can be part of a good financial plan and estate plan, especially for parents and grandparents.  The technique of making contributions to 529 Plans, as set forth above, can result in very substantial tax savings.  We suggest you consult with a knowledgeable attorney in the state where you live to help you decide if a 529 Plan should be part of your own estate plan.  We also suggest that you review the information available at the linked sites as well as from other sources.


Links to Other 529 Plan Resources


Pa Treasury - TAP 529

Guide to Understanding 529 Plans (PFD)

How Stuff Works - How 529 Plans Work

College Savings Plans Network

Morningstar Articles About 529 Plans

Merrill Lynch

SmithBarney

Independent 529 Plan (TIAA-CREF)





Note:  The statements contained in this Article are set forth here for information purposes only and are not intended to be legal advice.  You should consult a lawyer for legal advice about your own particular situation.  This Article does not attempt to provide all the detailed requirements of the plans or all the tax consequences that might result from various circumstances.  

We are not responsible for any information set forth at any of the linked web sites and make no representation about the accuracy of that information.


Notice Pursuant to Final Regulations Under Circular 230, effective June 20, 2005
The opinions contained in any communication on the web site are not intended or written to be used, and cannot be used, by any taxpayer for the purpose of avoiding penalties that may be imposed on the taxpayer under the Internal Revenue Code. 



Revised June 2005

© 2005 Marc H. Jaffe



Fromhold Jaffe & Adams
Attorneys at Law
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Villanova, Pennsylvania 19085

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