Tax News for Nonprofits

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Tax law changes all the time and, with the pandemic, it’s shifting more frequently than ever. Minor changes can add up to big savings (or big mistakes if you’re unaware of them). Here’s a roundup of the latest tax news that nonprofit accounting and finance professionals need to know. Our previous tax tips update may also be helpful.

Paycheck Protection Program Loan Forgiveness Is Deductible

Originally, the IRS ruled in Notice 2020-32 and Rev. Rul. 2020-27 that Paycheck Protection Program loan recipients could not deduct expenses that are normally deductible under the extent the payment of those expenses resulted in PPP loan forgiveness. However, that ruling became obsolete with Rev. Rul. 2021-2.

Congress clarified in the Consolidated Appropriations Act, 2021 (CAA), P.L. 116-260 that deductions are allowed for otherwise deductible expenses paid with the proceeds of a PPP loan that is forgiven. The tax basis and other attributes of the borrower’s assets are not reduced as a result of the loan. This was clarified in December 2020. There is now a safe harbor provision for those who filed a tax year 2020 return on or before Dec. 27, 2020, to deduct those expenses on their 2021 tax return rather than file amended returns or administrative adjustment requests if they are a “covered taxpayer” (as defined in the revenue procedure) and they satisfy all of the requirements for the time and manner of making the election to apply the safe harbor.

Food and Beverage Deductions

50% or 100%? That’s what everyone wants to know.

Typically, food and beverage deductions are 50%. A restaurant meal for business purposes, for example, counts as a 50% deduction.

However, the IRS temporarily increased it to 100%. Under Sec. 274(n)(1), a deduction for any expense for food or beverages is generally limited to 50% of the amount that would otherwise be deductible. The Consolidated Appropriations Act, 2021, P.L. 116-260 removed that limitation for amounts paid or incurred after Dec. 31, 2020, and before Jan. 1, 2023, for food or beverages provided by a restaurant (Sec. 274(n)(2)(D)).

Now, of course, we need to define “restaurant.” According to the definition that applies here, it is any establishment that prepares and sells food or beverages for immediate consumption on or off-premises. A coffee shop that sells breakfast sandwiches and coffee drinks for consumption on-premises or take away would count for 100% deduction but a kiosk or vending machine selling the same products does not.

So, schedule those breakfast, lunch, and dinner meetings as long as it’s safe to do so in your area. Now is the time to patronize local establishments for business meetings (and save your receipts for your accountant).

American Rescue Plan Adds to Wages Qualifying for Sections 3131 and 3132 Credits

The American Rescue Plan is another economic relief package for American families adversely affected by the continuing health crisis. The IRS sent a reminder that under this plan, employers with 500 or fewer workers can take a credit equal to the wages paid to employees for a paid day off to be vaccinated.

IRS Extends E-Signature

The IRS has extended its provision to accept e-signatures on many forms until December 31, 2021. The ongoing pandemic has necessitated that not only will they extend the deadline, but they are also adding more forms. Many of these forms can now be signed remotely, then printed or scanned and sent to the IRS, making it easier to complete required paperwork during the pandemic.

Welter Consulting

Welter Consulting bridges people and technology together for effective solutions for nonprofit organizations. We offer software and services that can help you with your accounting needs. Please contact Welter Consulting at 206-605-3113 for more information.

How the Pandemic Affects Compensated Absences: Something to Consider

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The global pandemic’s effects are still being felt in many areas. One such area is in the realm of accounting; specifically, the area of compensated absence.

What is compensated absence? It’s vacation and sick time. Many employees deferred vacation time during the pandemic since travel was so restricted. The result is a higher than usual amount of accrued compensated time off, which must be accounted for logically and systematically.

There are no FASB standards for the rate at which such time is accrued. Instead, organizations are urged to look at their record of accounting for such time off. Accountants may choose from the current rate or the likely compensation rate when employees are expected to redeem their vacation days.

The latter is easier said than done. Even though better awareness, knowledge, and testing for COVID-19 have kept much of the nation open, some employees may still be reluctant to take their vacation time. Nonprofits must develop a plan of action to handle the accrual of compensated time off.

Develop Your Plan for Compensated Time Off

To develop a plan for compensated time off, first, review your current definition of such time.

  • How does your organization define compensated time off? Many define it as vacation time, sick days, or personal days. Review your organization’s current definition and method of acquiring time off. For example, is vacation time off based on the number of days worked, or do all employees receive the same amount of time at the start of the calendar or fiscal year?
  • Does your policy allow employees to roll over such time and, if so, how long can they accrue it?
  • If they cannot roll over the time but must “use it or lose it,” are they compensated for it instead?
  • Have you made any emergency declarations, i.e., special arrangements, for employees during the pandemic?
  • Have you reviewed both accrued and vested rights? Are these in line with state and local laws and requirements?

Once you have the facts about your current policies and understand fully all of the considerations for paid time off, think about the following as you create your plan to account for compensated time off.

Accrual for Compensated Time Off

Take into account the substance and spirit of your organization’s vacation and sick leave policies, rather than the actual form. Does your organization provide a generous policy that goes above and beyond the legal rights of employees as governed by state and federal law? If so, then the liability for compensated time off should include all reasonable compensation likely to be paid.

Accountants should use historical data pertaining to compensating employee absences to make projections about the potential of unused accrued time off. This information can be used to estimate the value of lapsed compensated absences.

A spreadsheet can be helpful to estimate the possible adjusted journal entries. Having a computerized accounting system will also make the estimation process easier. Historic reports will show the average balance for accrued vacation and unpaid sick leave, which can be used as a basis to adjust for any anticipated increase due to the unusual years, thanks to COVID-19.

Welter Consulting

Welter Consulting bridges people and technology together for effective solutions for nonprofit organizations. We offer software and services that can help you with your accounting needs. Please contact Welter Consulting at 206-605-3113 for more information.

Common Functional Expense Allocation Errors—and How You Can Avoid Them

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One of the most important questions potential donors ask themselves when reviewing nonprofit financials is how an organization uses it funds. Donors want to know that a nonprofit uses them wisely and puts most of its money towards its programs. An analysis of expenses by nature and function can tell a compelling story to potential donors and make it clear that your nonprofit is a responsible steward of its funds.

But there are several common functional expense allocation errors that occur among many nonprofits. Is your organization making these mistakes?

7 Functional Expense Allocation Mistakes

  1. No expense allocation methodology: Now that GAAP requires nonprofits to disclose the methods they use to allocate costs among programs and various support functions, it’s more important than ever to ensure that you have a reasonable allocation method. It’s assumed that nonprofits will each choose their own allocation method. What’s important is that the method makes sense (is considered “reasonable”) and that it is applied consistently. Lack of a documented expense allocation methodology is a common mistake that is easily rectified.
  2. Incorrectly classifying management and general expenses: GAAP rules (FASB ASC 720-958-45-7) stipulate that various expenses should be allocated to management and general expenses. This includes payroll, human resources, and accounting costs. In years past, nonprofits had more leeway to allocate these expenses. If your organization hasn’t updated its allocation guidelines, now’s the time to fix this common mistake.
  3. Allocating too few costs to programs: Another common error is not allocating enough costs to actual programs. An example is an accounting professional whose salary expense is allocated to management, but they provide 100% of support to a particular program. In that case, their costs should be allocated to the program instead of to the overall payroll budget.
  4. Not considering joint costs: If an activity supports multiple purposes, consider allocating it as a joint cost. FASB ASC Subtopic 958-720, Not-for-Profit Entities-Other Expenses describes the reporting requirements. Creating a systematic and reasonable basis for allocating joint costs and applying it consistently helps rectify this error. Consider and choose from among several allocation methods, too, such as the physical-units method, the relative-direct-costs method, and standalone method.
  5. Providing the appropriate level of detail: It can be challenging to provide the appropriate level of detail for the natural component of expenses in the functional expense analysis. To find the best level of detail, consider the needs of your audience. What do they want and need to know? Find a happy medium between disclosing too much and too little information.
  6. Not allocating fundraising expenses: Check that the salaries allocated to fundraising expenses are reasonable. Many organizations fail to allocate fundraising expenses appropriately. Ask yourself if the amount you are currently allocating is reasonable. You may need to make some adjustments.
  7. Misclassifying investment-related activity: Under current GAAP requirements, direct internal and external investment related expenses should be netted on the statement of activities with the investment return. Based on the new presentation requirements, such expenses should be omitted from the functional expense analysis.

Professional Judgment Is Vital

Nonprofit accounting professionals must use their judgment when considering functional expense allocation. Knowing the common errors and keeping them in mind when reviewing your organization’s financials can help you make prudent decisions that are in the best interests of your nonprofit.

Welter Consulting

Welter Consulting bridges people and technology together for effective solutions for nonprofit organizations. We offer software and services that can help you with your accounting needs. Please contact Welter Consulting at 206-605-3113 for more information.

Gifts in Kind: Upcoming Changes to Presentation

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Philosophers tell us the only thing constant in the universe is change. When it comes to accounting rules, that seems to be the norm as well. The past year we had a little break from the constant stream of changes coming from FASB, but a new change to the presentation of gifts in kind is on the horizon. Here’s what nonprofits need to know about ASU 2020-07, changes to the presentation of gifts in kind.

What Are “Gifts in Kind”?

The term “gifts in kind” may refer to fixed assets or intangible assets. Examples of gifts in kind that are included in the updated accounting rules include fixed assets such as land, buildings, and equipment. It also includes the use of fixed assets, so if a donor allows you the use of a building, for example, that must be included as well.

Other donations must be included: utilities, food, clothing, medicines, and medical supplies. Lastly, intangible assets such as contributed services are also categorized as gifts in kind and should be described as such in your accounting documents.

5 Required Disclosures

Under the revised ASU 202-07, nonprofits are now required to disclose five things related to each item included as a gift in kind.

  1. Qualitative information
  2. Nonprofit policies
  3. Donor restrictions
  4. Valuation technique
  5. Principal market

Let’s unpack each one.

Under qualitative information, nonprofits are asked to disclose whether the asset was sold or utilized. If the asset was used by the nonprofit for its work, the disclosure should include information about which project the asset was used for and how it was used.

Nonprofit policies refer to the organization’s written policy regarding gifts in kind. Some organizations have written policies about how gifts in kind are monetized. For example, are assets sold at auction or sold in a charity shop? How are they valued? Such policies should be included as part of the description.

Donor restrictions include any conditions that donors place upon how the asset is used or disposed of; for example, if the donor restricts an item to use by the nonprofit rather than allowing it to be monetized.

Valuation techniques are described in FASB ASC Topic 820, Fair Value Measurement. The technique used to value items at initial recognition should be described and recorded.

Principal market (or most advantageous market) used to arrive at a fair value measure if it is a market in which the recipient not-for-profit is prohibited by a donor-imposed restriction from selling or using the contributed nonfinancial assets.

Reporting Changes to Gifts in Kind Are Retroactive

FASB has stated that these reporting changes should be applied retroactively, so nonprofits should begin immediately to assess gifts in kind and how they are reported. The amendments take effect for annual reporting periods beginning after June 15, 2021 (for example, fiscal years ending June 30, 2022, and December 31, 2022). And, if you’re so inclined, you may report early—FASB is allowing early adoption of the updated reporting standard.

Everything changes, and that includes FASB standards. If your organization accepts gifts in kind, now is the time to act on these updates.

Welter Consulting

Welter Consulting bridges people and technology together for effective solutions for nonprofit organizations. We offer software and services that can help you with your accounting needs. Please contact Welter Consulting at 206-605-3113 for more information.