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JHU Gift Policy

With the holidays quickly approaching, we would like to remind everyone of the policy changes surrounding cash and gifts purchased on departments non-sponsored funds. The important item to note is that the JHU policy which allows de minimis gifts of $100 or less per year only applies to non-cash gifts. Gift cards, such as an Amazon gift card are considered cash gifts per the IRS, do not fall under the de minimis rule, and would have to be treated as taxable to the employee. As such, they are not allowed. A summary of key points follows.

  • Gift Cards: Gift cards or gift certificates may not be purchased with University funds to be given as part of JHU employee programming, incentives or gift-giving
  • De Minimis Gifts: Gifts must be infrequent, non-cash gifts (such as a mug or T-shirt) that are valued cumulatively up to $100 per employee per calendar year. This threshold does not include auxiliary costs (such as engraving, embroidering or shipping fees).
    • Infrequent non-cash gifts given during the same calendar year that, when combined, are in excess of $100 must be considered compensation and reported in the Form W-2. Should such expenses be reimbursed by the University, they must be processed by Payroll Shared Services and included in the employee’s taxable income.

Click here for a copy of the full updated policy released in February 2023 which includes additional details. If you have any questions regarding tax withholding for gifts in excess of $100 in a calendar year, please direct inquiries to the University Tax Office at


Kelsey Bennett