You Make the Call - Oct. 30, 2025

Question: Jordan, an unmarried taxpayer, has a taxpayer identification number (TIN), while her daughter, Sabrina, has a Social Security number (SSN). In 2025, Sabrina attended her first year at an eligible educational institution as a full-time student. A 1098-T, Tuition Statement, was issued in Sabrina’s name reporting the tuition paid. Jordan will claim Sabrina as a dependent. Can Jordan claim the American opportunity tax credit (AOTC) in 2025, assuming she meets all the other requirements? Are there changes Jordan should be aware of for 2026? 
 
Answer: Yes, Jordan can claim the AOTC for Sabrina in 2025. However, the OBBBA added a new requirement. For tax years starting after Dec. 31, 2025, taxpayers must provide a valid SSN for themselves or at least one spouse if filing jointly to claim the AOTC. Additionally, if the student is neither the taxpayer nor the spouse, their SSN must be reported. In Jordan's case, her daughter's SSN must be included on the return since her daughter is the student.  

ITINs no longer meet this requirement. As such, unless Jordan obtains an SSN valid for work, she cannot claim the credit in 2026. If a required SSN is missing, the IRS can treat this omission as a mathematical or clerical error, which may result in the denial of the credit without an audit. 

This new provision under the OBBBA will be effective for tax years beginning after Dec. 31, 2025, which means it applies to tax returns filed in 2027 for the 2026 tax year.