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IRS Issue Snapshot discusses deduction limits for “combination” retirement plans
The IRS occasionally publishes “Issue Snapshots” to provide an overview of a tax topic for its employees. Recently, the tax agency released “Issue Snapshot: Combined Limits under IRC Section 404(a)(7).” The publication discusses the limits on contribution deductions when an employer provides both a defined contribution (DC) and defined benefit (DB) retirement plan — commonly referred to as a “combination” plan.
Qualified plan rules
Generally, an employer’s contributions to a qualified retirement plan are deductible if they’re ordinary and necessary expenses of carrying on a trade or business and are compensation for services rendered.
However, an employer’s qualified plan contributions are limited. For example, an employer sponsoring a DC plan, such as a 401(k), is allowed a deduction for contributions of up to 25% of the compensation paid or accrued to plan beneficiaries during the employer’s tax year.
If the employer contributes to two or more DC plans, those plans are considered a single plan for purposes of applying the 25% limit. Meanwhile, the tax code provides a separate maximum deduction for contributions to a DB plan (often called a “pension plan.”)
Combo plan limits
If an employer has a combination plan, Section 404(a)(7) of the tax code limits that employer’s contribution deductions. These limits apply only in a tax year when:
- At least one participant benefits under both plans and receives allocations other than elective deferrals in the DC plan (called “overlapping coverage”),
- The DB plan is exempt from Pension Benefit Guaranty Corporation coverage, and
- Both the DB and DC plans are single-employer plans.
If a DB and DC plan have overlapping coverage and employer contributions to the DC plan (other than elective deferrals) don’t exceed 6% of the aggregate compensation of DC plan beneficiaries, the limit on combination plans doesn’t apply.
However, if there’s overlapping coverage and the employer contributions to the DC plan (other than elective deferrals) do exceed 6% of aggregate compensation of the DC beneficiaries, then the combination plan limits are applied by considering only those DCs that exceed 6%.
Calculating the limit
According to the Issue Snapshot, the separate deduction limits for the DB and DC plans should be calculated before applying the Sec. 404(a)(7) limits. Thus, the combined deduction limit on contributions to a single-employer DB plan and a single-employer DC plan that have overlapping coverage is the greater of:
- 25% of the compensation otherwise paid or accrued during the tax year to beneficiaries, or
- The greater of the minimum required contribution to the DB plan for the plan year or the excess of the funding target over the plan’s assets for that plan year.
IRS insight
According to the IRS, “Issue Snapshots may not contain a comprehensive discussion of all pertinent issues, law or … interpretation of current law.” However, they do provide insight into what the tax agency is looking at. If your organization offers a combination retirement plan, we can help you assess the tax impact.
© 2021
Checkpoint Marketing for Firms
THOMSON REUTERS
FASB offers practical expedient for private companies that issue share-based awards
On October 25, the Financial Accounting Standards Board (FASB) issued a simpler accounting option that will enable private companies to more easily measure certain types of shares they provide to both employees and nonemployees as part of compensation awards. Here are the details.
Complex rules
Many companies award stock options and other forms of share-based payments to workers to promote exceptional performance and reduce cash outflows from employee compensation. But accounting for these payments can be confusing and time-consuming, especially for private companies.
To measure the fair value of stock options under existing U.S. Generally Accepted Accounting Principles (GAAP), companies generally use an option-pricing model that factors in the following six variables:
- The option’s exercise price,
- The expected term (the time until the option expires),
- The risk-free rate (usually based on Treasury bonds),
- Expected dividends,
- Expected stock price volatility, and
- The value of the company’s stock on the grant date.
The first four inputs are fairly straightforward. Private companies may estimate expected stock price volatility using a comparable market-pricing index. But the value of a private company’s stock typically requires an outside appraisal. Whereas public stock prices are usually readily available, private company equity shares typically aren’t actively traded, so observable market prices for those shares or similar shares don’t exist.
To complicate matters further, employee stock options are also subject to Internal Revenue Code Section 409A, which deals with nonqualified deferred compensation. The use of two different pricing methods usually gives rise to deferred tax items on the balance sheet.
Simplification measures
Accounting Standards Update (ASU) No. 2021-07, Compensation-Stock Compensation (Topic 718): Determining the Current Price of An Underlying Share for Equity-Classified Share-Based Awards, applies to all equity classified awards under Accounting Standards Codification Topic 718, Stock Compensation.
The updated guidance allows private companies to determine the current price input in accordance with the federal tax rules, thereby aligning the methodology used for book and federal income tax purposes. Sec. 409A is referenced as an example, but the rules also include facts and circumstances identified in Sec. 409A to consider for reasonable valuations. The practical expedient will allow private companies to save on costs, because they’ll no longer have to obtain two independent valuations separately for GAAP and for tax purposes.
Right for your company?
Private companies that take advantage of the practical expedient will need to apply it prospectively for all qualifying awards granted or modified during fiscal years beginning after December 15, 2021, and interim periods within fiscal years beginning after December 15, 2022. Early application, including application in an interim period, is permitted for financial statements that haven’t yet been issued or made available for issuance as of October 25, 2021. Contact your CPA for more information.
© 2021
Checkpoint Marketing for Firms
THOMSON REUTERS
Factor in taxes if you’re relocating to another state in retirement
Are you considering a move to another state when you retire? Perhaps you want to relocate to an area where your loved ones live or where the weather is more pleasant. But while you’re thinking about how many square feet you’ll need in a retirement home, don’t forget to factor in state and local taxes. Establishing residency for state tax purposes may be more complicated than it initially appears to be.
What are all applicable taxes?
It may seem like a good option to simply move to a state with no personal income tax. But, to make a good decision, you must consider all taxes that can potentially apply to a state resident. In addition to income taxes, these may include property taxes, sales taxes and estate taxes.
If the state you’re considering has an income tax, look at what types of income it taxes. Some states, for example, don’t tax wages but do tax interest and dividends. And some states offer tax breaks for pension payments, retirement plan distributions and Social Security payments.
Is there a state estate tax?
The federal estate tax currently doesn’t apply to many people. For 2021, the federal estate tax exemption is $11.7 million ($23.4 million for a married couple). But some states levy estate tax with a much lower exemption and some states may also have an inheritance tax in addition to (or in lieu of) an estate tax.
How do you establish domicile?
If you make a permanent move to a new state and want to make sure you’re not taxed in the state you came from, it’s important to establish legal domicile in the new location. The definition of legal domicile varies from state to state. In general, domicile is your fixed and permanent home location and the place where you plan to return, even after periods of residing elsewhere.
When it comes to domicile, each state has its own rules. You don’t want to wind up in a worst-case scenario: Two states could claim you owe state income taxes if you establish domicile in the new state but don’t successfully terminate domicile in the old one. Additionally, if you die without clearly establishing domicile in just one state, both the old and new states may claim that your estate owes income taxes and any state estate tax.
The more time that elapses after you change states and the more steps you take to establish domicile in the new state, the harder it will be for your old state to claim that you’re still domiciled there for tax purposes. Some ways to help lock in domicile in a new state are to:
- Change your mailing address at the post office,
- Change your address on passports, insurance policies, will or living trust documents, and other important documents,
- Buy or lease a home in the new state and sell your home in the old state (or rent it out at market rates to an unrelated party),
- Register to vote, get a driver’s license and register your vehicle in the new state, and
- Open and use bank accounts in the new state and close accounts in the old one.
If an income tax return is required in the new state, file a resident return. File a nonresident return or no return (whichever is appropriate) in the old state. We can help file these returns.
Before deciding where you want to live in retirement, do some research and contact us. We can help you avoid unpleasant tax surprises.
© 2021
Checkpoint Marketing for Firms
THOMSON REUTERS
Would you like to establish a Health Savings Account for your small business?
With the increasing cost of employee health care benefits, your business may be interested in providing some of these benefits through an employer-sponsored Health Savings Account (HSA). For eligible individuals, an HSA offers a tax-advantaged way to set aside funds (or have their employers do so) to meet future medical needs. Here are the important tax benefits:
- Contributions that participants make to an HSA are deductible, within limits.
- Contributions that employers make aren’t taxed to participants.
- Earnings on the funds in an HSA aren’t taxed, so the money can accumulate tax free year after year.
- Distributions from HSAs to cover qualified medical expenses aren’t taxed.
- Employers don’t have to pay payroll taxes on HSA contributions made by employees through payroll deductions.
Eligibility rules
To be eligible for an HSA, an individual must be covered by a “high deductible health plan.” For 2021, a “high deductible health plan” is one with an annual deductible of at least $1,400 for self-only coverage, or at least $2,800 for family coverage. (These amounts will remain the same for 2022.) For self-only coverage, the 2021 limit on deductible contributions is $3,600 (increasing to $3,650 for 2022). For family coverage, the 2021 limit on deductible contributions is $7,200 (increasing to $7,300 for 2022). Additionally, annual out-of-pocket expenses required to be paid (other than for premiums) for covered benefits for 2021 cannot exceed $7,000 for self-only coverage or $14,000 for family coverage (increasing to $7,050 and $14,100, respectively, for 2022).
An individual (and the individual’s covered spouse, as well) who has reached age 55 before the close of the tax year (and is an eligible HSA contributor) may make additional “catch-up” contributions for 2021 and 2022 of up to $1,000.
Contributions from an employer
If an employer contributes to the HSA of an eligible individual, the employer’s contribution is treated as employer-provided coverage for medical expenses under an accident or health plan. It’s also excludable from an employee’s gross income up to the deduction limitation. Funds can be built up for years because there’s no “use-it-or-lose-it” provision. An employer that decides to make contributions on its employees’ behalf must generally make comparable contributions to the HSAs of all comparable participating employees for that calendar year. If the employer doesn’t make comparable contributions, the employer is subject to a 35% tax on the aggregate amount contributed by the employer to HSAs for that period.
Taking distributions
HSA distributions can be made to pay for qualified medical expenses, which generally means expenses that would qualify for the medical expense itemized deduction. Among these expenses are doctors’ visits, prescriptions, chiropractic care and premiums for long-term care insurance.
If funds are withdrawn from the HSA for other reasons, the withdrawal is taxable. Additionally, an extra 20% tax will apply to the withdrawal, unless it’s made after reaching age 65, or in the event of death or disability.
HSAs offer a flexible option for providing health care coverage and they may be an attractive benefit for your business. But the rules are somewhat complex. Contact us if you’d like to discuss offering HSAs to your employees.
© 2021
Checkpoint Marketing for Firms
THOMSON REUTERS
Data visualization: A picture is worth 1,000 words
Graphs, performance dashboards and other visual aids can help managers, investors and lenders digest complex financial information. Likewise, auditors also use visual aids during a financial statement audit to quickly identify trends and anomalies that warrant attention.
Powerful tool
Your auditor uses many tools and techniques to validate the accuracy and integrity of your company’s financial records. Data visualization — using a picture to show a relationship between two accounts or how a metric has changed over time — can help improve the efficiency and effectiveness of your audit.
Microsoft Excel and other dedicated data visualization software solutions can be used to generate various graphs and charts that facilitate audit planning. These tools can also help managers and executives understand the nature of the auditor’s testing and inquiry procedures — and provide insight into potential threats and opportunities.
4 Examples
Here are four examples of how auditors might use visualization to leverage your company’s data:
1. Employee activity in the accounting department. Line graphs and pie charts can help auditors analyze the number, timing and value of journal entries completed by each employee in your accounting department. Such analysis may uncover an unfair allocation of work in the department — or employee involvement in adjusting entries outside of their assigned area of responsibility. Managers can then use these tools to reassign work in the accounting department, pursue a fraud investigation or improve internal controls.
2. Activity in accounts prone to fraud and abuse. Auditors closely monitor certain high-risk accounts for fraud and errors. For example, data visualization can shine a spotlight on the timing and magnitude of refunds and discounts, highlight employees involved in each transaction and potentially uncover anomalies for additional scrutiny.
3. Journal entries prior to the end of the accounting period. Auditors analyze and confirm the timing and magnitude of your journal entries leading up to a month-end or year-end close. Timeline charts and other data visualization tools can help auditors understand trends in your company’s activity during a month, quarter or year.
4. Forecast vs. actual. Line graphs and bar charts can show how your company’s actual performance compares to budgets and forecasts. This can help confirm that you’re on track to meet your goals for the period. Conversely, these tools can also uncover significant deviations that require further analysis to determine whether the cause is internal (for instance, fraud or inefficiency) or external (for instance, cost increases or deteriorating market conditions). In some cases, management will need to revise budgets based on the findings of this analysis — and potentially take corrective measures.
Show and tell
Data visualization allows your data to talk. Auditors use these tools to better understand your operations and guide their risk assessment, inquiries and testing procedures. They also use visual aids to explain complex matters and highlight trends and anomalies to management during the audit process. Some graphs and charts can even be added to financial statement disclosures to communicate more effectively with stakeholders. Contact us for more information about using data visualization in your audit and beyond.
© 2021
Checkpoint Marketing for Firms
THOMSON REUTERS
