Form 15714 is the document a state has to send the Internal Revenue Service to join the new federal scholarship tax credit, and for the first year the deadline for sending it is January 1, 2027. The temporary regulations published October 2, 2026, give states until February 15, 2027, only to perfect that election by submitting a list of scholarship-granting organizations. The same rules say the organizations on the list must meet an operating test of their own: scholarships for at least ten students who do not all attend the same school.
Form 15714 first, the organization list second
The Federal Register document sets out the sequence in plain terms. “For calendar year 2027, a State must submit an advance election on Form 15714 on or before January 1, 2027,” it says. A state may then “perfect its advance election by submitting its State SGO list on or before February 15, 2027.”
The two dates are not interchangeable. January 1 is the date the election itself must be in. February 15, about six weeks later, is the date for the supporting paperwork, the list of organizations the state has certified.
The 2027 calendar is the exception
The compressed schedule applies to 2027 only. For every later year, the regulation moves the window to the calendar before the credit year: “During the last three months of the immediately preceding calendar year or on January 1 of the year for which the election is being made, a State may make its election.” In practice, an election for 2028 would be made between October 1 and December 31, 2027, or on January 1, 2028.
The election is a decision for state government, and the text says who makes it. It “must be made by the Governor of the State or by such other individual, agency, or entity as is designated under State law.” The Treasury Department’s announcement describes participation as a voluntary opt-in and says 30 states have already elected to participate.
The ten-student test belongs to the organizations
The temporary regulations define a scholarship-granting organization by pointing to section 25F(c)(5) of the tax code, without restating the statutory conditions. The IRS spelled out those conditions in Notice 2025-70: “The organization must provide scholarships to 10 or more students who do not all attend the same school.”
That wording differs from a count of schools. An organization funding ten students at a single school fails it, while one funding ten students split across two schools can pass. The requirement describes how an organization operates, and it rests on the organization alone. The regulation’s definition of a qualified contribution, a cash gift the donor designates as such at the time of giving, carries no school-count condition.
The practical effect is a division of labor with three layers. Governors or their designees answer to the Form 15714 and February 15 dates. Organizations answer to the notice’s operating tests and to the registration and segregated-account rules. Donors, under the Federal Register text, make cash gifts and designate them, and receive a written acknowledgement from the organization by January 31 of the following year. Families of students appear in the rules only as the people whose household income an organization must check, never as parties who must meet a test.
What else the notice asks of an organization
The notice lists further operating conditions. An organization cannot spend less than 90 percent of its income on scholarships for eligible students, and it cannot earmark contributions for particular students. It must prioritize continuing students and siblings of earlier recipients and must check that household income does not exceed 300 percent of area median gross income. It may not award scholarships to disqualified persons.
The regulation adds a bookkeeping rule at the state level. States must certify that an organization keeps “a segregated section 25F account exclusively for qualified contributions” so those gifts are not co-mingled with other money. An organization registers electronically through the IRS SGO portal with its name, employer identification number, address, telephone number and year of formation.
A safe harbor and a calendar that still has gaps
Treasury’s announcement describes an operational safe harbor for organizations whose activities are at least 85 percent scholarship-focused. The announcement quotes IRS chief executive Frank J. Bisignano saying the rules give “states, scholarship-granting organizations, and taxpayers” clarity to prepare for the credit.
The credit itself reaches taxpayers only for taxable years ending after December 31, 2026, according to the Federal Register text, and the companion proposed rule remains a proposal. The state steps above are therefore the earliest dated actions in the program: a Form 15714 filing by January 1, 2027, and a state list by February 15, 2027. The Federal Register document names Constance Chien and Andrew Fahmy as the IRS contacts for questions on the temporary rules.
The refund check that never arrived
Refund checks can go missing in the mail. A taxpayer whose check never showed up has to ask for a trace, and the request has its own form and its own sequence of steps.
The IRS Refund Recovery Kit is a 13-page kit that lays out the refund-trace steps (Form 3911) and includes a refund status tracker spreadsheet for logging each date and reply.
Follow the Form 3911 refund-trace steps for a refund check that never arrived →
This article was produced with AI assistance and checked against the Federal Register, IRS and Treasury pages cited above before publication.
Warren Cohen is a finance writer based in Phoenix, Arizona, covering personal finance topics including credit, banking, and beginner investing. He earned his degree in business administration from Arizona State University and began his career working in consumer finance, where he gained direct experience with lending and credit systems. He now writes for personal finance websites and fintech platforms, focusing on clear, practical content that helps readers make informed financial decisions.
