Considering Book/Tax Differences in Patronage and Tax Computations

By: Dave Thomsen, CPA, Partner |  email

One of the best parts of working with our cooperative clients is helping them with the annual decision of how much of their earnings to allocate back to members as patronage dividends. There are rules to follow in order to protect the ability to deduct the allocation for income tax purposes. Many items come into play, such as: is the cooperative "exempt" or "non-exempt" for tax purposes, will patronage dividends be in the form of "qualified" or "non-qualified" allocations, and is the allocation based on "book" income or "tax" income.

Most of our clients have historically based their patronage dividend allocations on a tax basis, and there are several book/tax differences that can have a big impact on the patronage dividend computation. Some of these differences are temporary while others are permanent, and many of you have seen the significant effect they have had on recent patronage dividend and income tax computations at your cooperative. Several of the more common book/tax differences we work with on an annual basis and how they are handled differently for book and tax purposes are as follows:

Topic Book/GAP Tax
Depreciation Deduct over useful life

Deduction based on tax tables, Section 179, bonus depreciation

Section 199 - DPAD N/A Deduct as computed, often limited by wages
Inventory capitalization - 263a N/A Capital certain purchasing, handling and storage costs
Inventory reserves Deductible when established Not deductible
Bad debt reserves Deductible when established Not deductible
Meals & entertainment Deduct in full 50% deductible
Lobbying/political contributions     Deduct in full Not deductible
Accrued salaries, bonuses and vacations   Deduct in full when accrued Deduct if paid within 2 1/2 months of year end
Pension costs Deduct as paid or accrued per actuarial computations  Deduct as paid 
Nonqualified allocation issued Increase in members' Equity Not deductible until redeemed
Nonqualified allocation received Recognize as income Income deferred until redeemed 

We will continue to work with you to help you understand the effect of these differences between your audited financial statements and tax return, and the effect they have on your patronage dividend computation. In the meantime, if you have questions or would like to discuss some patronage dividend and income tax planning prior to your year end please let us know.