My spouse's employer offers a tuition reimbursement benefit. They contribute a certain amount which is sent directly to the school my daughter attends. I am aware that if a student recieves a regular scholarship from the school, that a non-qualified 529 Plan withdrawl can be made in an amount equal to the scholarship recieved, and the 10% penalty is waved. I am aware that taxes would be paid on the earnings portion only of the distribution. My question is: is the amount of the employer tuition contribution benefit treated in the same way?