Basic Cooperative Taxation

Basic Cooperative Taxation
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Tax = (income - deductible expenses) x rate(s)
Corporate Income Tax Tenets The corporation is a taxable entity Not all income is taxable Contributions to capital are treated differently than operating income Tax = (income - deductible expenses) x rate(s) This is a simplistic view of how the corporate income tax works, but a useful one to frame our discussion of cooperative income tax treatment.

Tax Treatment by Business Type
Times Earnings Subject to Tax Level Proprietorship 1 Owner Partnership Owners LLC Limited Co-op Association Corporations Investor-General 2 Corporation / Owners Subchapter S Cooperative Some people assert that cooperatives have an unfair advantage over their competitors because cooperative earnings are only subject to a single tax. But in truth, most business structures and most businesses qualify for single tax treatment. Only investor-general business corporations are subjected to double taxation, once when profits are earned and a second time when they are distributed to shareholders as dividends.

Benefit Of Single Tax Treatment
General Business Corporation Single Tax Entity (Co-op) Taxable Income $40,000 Corporate Income Tax (15%) 6,000 Passthrough $34,000 Personal Income Tax (25%) 8,500 10,000 Value to Owners $25,500 $30,000 Tax Savings $4,500 This example illustrates that single tax treatment can be a significant benefit to eligible entities, including cooperatives.

Subchapter T Internal Revenue Code Sections 1381-1388
Home to the basic rules establishing single tax treatment for co-ops Applies to any corporation “operating on a cooperative basis,” except…

Utility Cooperatives Electric and Telecommunications Co-ops are tax exempt if at least 85 percent of their income is from providing service to members, Code sec. 501(c)(12) If a Utility cooperative doesn’t meet the 85 percent test, then, under common law, it is taxed similarly to a Subchapter T cooperative

Other Exempt Cooperatives
Credit Unions without capital stock organized and operated for mutual purposes and without profit, Code sec. 501(c)(14)(A) Cooperative Hospital Service Organizations organized and operated solely to purchase supplies and provide administrative services to members, Code sec. 501(e)

Sales of Consumer Goods
Allocations of patronage-sourced earnings from the sale of “personal, living, or family items” are free of taxation at both the co-op and the patron levels, Code sec. 1385(b)(2) For example, if a patron purchases a computer through a cooperative for business use, any related patronage refund is taxable income to that patron. But if the computer is purchased for personal use, the patron need not include any related patronage refund in taxable income.

Subchapter T Applies to any corporation “operating on a cooperative basis.” What does that mean? Not defined in the Code Essentially, it means returns earnings to users (patrons) on the basis of use (patronage) by issuing them patronage refunds In simplest terms, the “operating on a cooperative basis” standard is met if a corporation allocates its earnings as patronage refunds. Theoretically, Exxon Mobil could qualify for Subchapter T tax treatment if it allocated earnings to people who bought its gas on the basis of how much gas each purchased, rather than to shareholders on the basis of how much stock each shareholder owned.

Basic Cooperative Tax Rule
Net margins (earnings) on business conducted with or for patrons

Net margins (earnings) on business conducted with or for patrons Are taxable income to only the co-op or the patron One advantage a cooperative has over other single-tax entities is that a co-op can elect to pay the single tax initially at the entity level and later transfer that liability to its patrons at a time of its choosing. We’ll see how this works later in our discussion.

Net margins (earnings) on business conducted with or for patrons Are taxable income to only the co-op or the patron If distributed or allocated to patrons The distribution or allocation of earnings must be made to a patron of the cooperative. Payments to persons who do not do business with the cooperative are not eligible for single tax treatment as a patronage refund.

Net margins (earnings) on business conducted with or for patrons Are taxable income to only the co-op or the patron If distributed or allocated to patrons On the basis of business done with the cooperative Finally, the amount distributed or allocated to each patron must be based on the quantity or value of business done with or for that patron. A couple of points to remember. First, a patronage refund must be based on current year’s earnings. If a cooperative has no earnings, it can’t pay a patronage refund. Later in this module we’ll discuss how this can impact capital management and tax planning. And if a cooperative has earnings, the patronage refund for that year can not be greater than those earnings. Second, earnings not directly related to business with or for patrons are subject to double taxation, Distinguishing patronage-sourced and nonpatronage-sourced income is covered in the NSAC Advanced A&A course.

Patronage Refund The Internal Revenue Code definition of a Patronage Dividend (Refund) is An amount paid by a cooperative to a patron Based on the quantity or value of business done with the co-op Under a pre-existing legal obligation Determined by net margins on business with all patrons A couple of points to notice in the technical Internal Revenue Code definition of a patronage refund. First, the Code refers to the allocation or distribution as a patronage “dividend.” However, most people working for or with cooperatives generally use the more traditional term patronage “refund.” This keeps it clear in peoples’ minds that the payment is a return based on business conducted with the entity and not a true dividend, which is a return based on shares owned. Second, the Code definition introduces the concept of the pre-existing legal obligation. In other words, there must be a legally binding agreement to pay earnings to that patron as a patronage refund before the underlying transaction that generates the amount refunded takes place.

Patronage Refund If ABC Cooperative earned $1,000 last year, and
ABC Co-op did 6 percent of its business with Ms. Jones, then Ms. Jones is entitled to a Patronage Refund of $60 ($1,000 x .06) This example, from earlier in our course, is repeated here to refresh your memory on how the patronage refund is calculated.

“Patron” vs. “Member” Patron Member
A person with or for whom a co-op does business “on a cooperative basis;” that is, a person who is eligible to receive a patronage refund Member A person allowed to vote on issues decided by the membership Many cooperative members, directors, and employees use these terms interchangeably. But as a professional working with or for cooperatives, it is important for you to recognize the distinction. “Patron” is a matter of finance and taxation. “Member” is a matter of control and governance. They are often one and the same. But a person can be a patron (a person entitle to a patronage refund) without being a voting member of the cooperative. And a person can be a member (entitled to vote) but not a patron (doesn’t get a patronage refund).

Payment Period The time period during which a cooperative can make a patronage refund eligible for single tax treatment. It starts at the beginning of the tax year and ends: Subchapter T Co-ops 8½ months after close of tax year Exempt Co-ops 4½ months after close of tax year Taxable Utility Co-ops 2½ months after close of tax year To be eligible for single tax treatment, a patronage refund must be made in a timely manner, which is defined as from the beginning of a tax year until the time the cooperative has to file its tax return. Almost all cooperatives wait until the financial results for the year are determined and then make a single patronage refund payment toward the end of the payment period. But the flexibility does exist to make an interim payment during the tax year if the cooperative leadership determines this is prudent and appropriate under the circumstances.

Payment Options – Patronage Refund
Cash Distribution Retain the money, credit it to patron equity accounts, issue written notices of allocation Qualified Nonqualified This example, from earlier in our course, is repeated here to refresh your memory on how the patronage refund is calculated.

Taxes: Cash Patronage Refund
A Patronage Refund made as a cash distribution to patrons is Deductible by the co-op in year earned Taxable to the patron in year received

Taxes: Qualified Allocation
A qualified allocation of a retained patronage refund is taxed just like cash. It is Deductible by the co-op in year earned Taxable to the patron in year received The tax liability for a qualified allocation passes through the cooperative to the patron at the time the allocation is made. So the patron must include in taxable income, for the year the notice of the allocation is received, both the portion of the patronage refund received in cash and the portion retained and allocated on the books of the co-op as an equity investment by the patron.

Taxes: Qualified Allocation
A qualified allocation of a retained patronage refund is taxed just like cash. It is Deductible by the co-op in year earned Taxable to the patron in year received Redemption is a nontaxable event The tax liability passes to the patron at the time the qualified allocation is received. So when the cooperative redeems a qualified allocation for cash in a later year, the money received in the later year is not taxable income to the patron.

Tax Treatment of Cooperative & Patron Cash & Qualified Allocation
Expenses Income Crop $600 Other $300 Total $900 Income $1,000 Margin $100 Refund $100 Taxable Income $0 Taxable Income $700 In this example, the cooperative pays the patron $600 for the patron’s crop and incurs $300 in additional expenses marketing that crop, for a total of $900 in expenses related to marketing the patron’s crop. The co-op realizes $1,000 on the sale of that product. Any business is allowed to deduct the payment to the producer for the crop ($600) and other expenses ($300). A cooperative may also deduct the margin earned when it sells the producer's crop ($100), provided the cooperative returns the margin to the patron as a qualified patronage refund allocation. Thus the cooperative has no taxable income on those transactions. The patron includes the $600 crop payment and the $100 patronage refund in taxable income.

Qualifying a Patronage Refund
At least 20 percent payout in cash Here is the instance where the Tax Code usurps board authority over the distribution of patronage refunds. If a portion of a patronage refund is to be treated as a “qualified” allocation, a minimum of 20 percent of the refund must be paid in cash.

If ABC Cooperative earned $1,000 last year, and ABC Co-op did 6 percent of its business with Ms. Jones, then Ms. Jones is entitled to a patronage refund of $60 ($1,000 x .06) At least 20 percent of the patronage refund ($12) must be paid in cash So, to continue the earlier example, if Ms. Jones is to receive her patronage refund as a “qualified allocation,” at least 20 percent of the refund ($12) must be paid to her in cash and no more than 80 percent ($48) can be retained by her cooperative.

At least 20 percent payout in cash Patron consents to include entire allocation in taxable income Patron “consent” means the patron makes a legally binding commitment to include the entire patronage refund in taxable income.

Obtaining Patron Consent
Bylaw The Internal Revenue Code provides patrons can consent to include their patronage refunds in taxable income in any one of three ways. The first is through joining a cooperative with an appropriate bylaw providing that members agree to include the patronage refunds in taxable income. Most cooperative bylaws make consent a condition of membership. Two points to remember. First, the consent must be an informed consent. So whoever signs up new members must explain the bylaw when a new member joins your cooperative. Second, bylaws are only binding on members. So another method must be used to create consent from nonmember patrons.

Bylaw Written Consent Form The second method of obtaining consent is to have the patron sign a separate written consent form. This is the primary method used to secure consent from nonmember patrons. But it can also be used to get a record of consent from member patrons.

Bylaw Written Consent Form Endorsing and Cashing Qualified Patronage Refund Check The third method of obtaining consent is to have the patron endorse and cash a qualified patronage refund check for the cash portion of the refund. A qualified patronage refund check includes a statement on the back that endorsing and cashing the check constitutes consent. Some co-ops use this as a back-up to the first two mechanisms.

Taxes - Nonqualified Allocation
Year of Issuance Taxable to co-op in year earned Not taxable to patron in year received Earlier we mentioned that cooperatives, unlike other single-tax entities, have the option to have the entity absorb the single tax due, at least initially, on patronage refunds. The tool used to implement this option is the nonqualified allocation. If the retained portion of a patronage refund is a nonqualified allocation, the cooperative includes the amount of the allocation in taxable income for the year the amount of the allocation is earned. The patron does not report the allocation as taxable income in the year received. To create a nonqualified allocation, a cooperative simply does not do what is required to “qualify” it. This usually means not paying any cash refund or stating in the allocation notice sent to patrons that the allocation is not a qualified allocation.

Taxes - Nonqualified Allocation
Year of Issuance Taxable to co-op in year earned Not taxable to patron in year received Year of Redemption Deductible by co-op in year redeemed Taxable to patron in year redeemed In the year that the nonqualified allocation is redeemed for cash, the tax liability is transferred to the patron. The cooperative deducts the amount paid to patrons in redemption of the nonqualified allocations. The patron includes the amount of cash received in redemption of the nonqualified allocation in taxable income for the year the cash is received.

Tax Treatment of Cooperative & Patron Non-Qualified Allocation
Expenses Income Crop $600 Other $300 Total $900 Income $1,000 Margin $100 Refund $100 Taxable Income $100 Taxable Income $600 For the year that a nonqualified allocation is made, the accounting and tax results in our example are the same as with the qualified allocation, except with a nonqualified allocation the $100 earned on transactions with the patron is included in the co-op’s taxable income for the year earned. The patron reports only the $600 received for product delivered to the co-op.

Tax Treatment of Cooperative & Patron – Nonqualified Allocation, When Redeemed
The cooperative is entitled to a refund of the tax it paid on the $100 of taxable income it reported in the year the nonqualified were issued (special rules cover intervening changes in tax rates) The patron includes the $100 received in redemption of the nonqualified in taxable income for the tax year in which the cash is received

Per-Unit Retains Portion of sales proceeds
Retained by a marketing cooperative Based on dollar value or volume of products marketed for each patron Tax treatment of per-unit retain financing is similar to that of retained patronage refunds. The allocations can be either “qualified” or “nonqualified” with the same tax treatments available as for retained refunds. One difference is that there is no requirement for a 20 percent cash payout to qualify a per-unit retain.

Per-Unit Retains If Mr. Jones was due $10,000 for product delivered last year, and ABC Co-op collected a per-unit retain of 3 percent of the sales proceeds, then Mr. Jones receives $9,700 cash and a per-unit retain allocation of $300 ($10,000 x .03) Tax treatment is similar to patronage refunds, except no 20% cash payout is needed to “qualify” the retain, only consent If a cooperative is marketing product, per-unit retain financing has the advantage over retained patronage refunds of being a more stable and predictable source of equity. Most cooperatives will have sales, even if they don't generate earnings. But if the members are having a bad year, per-unit retains can lead to a member relations problem as the members may not want the co-op deducting any amount from their payments for product delivered. Determining whether to use per-unit retains and if you do, how high to set the retain percentage each year, is one example of the difficult equity accumulation issues that can confront directors, managers, and advisers working for or with cooperatives.

Non-Exempt Utility Co-ops
Taxed under rules in effect when Subchapter T was enacted into law, in 1962 Patronage refunds deductible by co-op under Revenue Act of 1951 Courts had held that redemption of retained patronage refunds was uncertain, so the value of the retains wasn't income to patrons until they were actually redeemed for cash So, non-exempt utility co-ops can claim a deduction for patronage refunds when issued and patrons don't have to include the value of the retain in income until it is redeemed for cash

Exempt Utility Co-ops All income is exempt from tax at the co-op level under I.R. Code section 501(c)(12) Patrons of exempt utility co-ops are also able to delay reporting the value of retained patronage refunds as income until they are redeemed for cash

Section 521 Farmer cooperatives Meeting several organizational tests
Can deduct dividends on stock Can deduct nonpatronage income distributed to patrons on a patronage basis Let’s briefly cover a couple of other tax items before moving on to an exercise on Subchapter T tax treatment. Section 521 of the Internal Revenue Code allows farmer co-ops meeting several stringent organizational tests to take two deductions not available to other cooperatives: 1. They can deduct dividends paid on stock 2. They can also deduct any nonpatronage income distributed to patrons on the basis of patronage Section 521 is not used by many co-ops today, as the cost of complying with the limitations often exceeds the benefit of the tax breaks.

Section 521 Farmer cooperatives Meeting several organizational tests
Can deduct dividends on stock Can deduct Nonpatronage income distributed to patrons on a patronage basis Often incorrectly called “tax exempt” co-ops Section 521 co-ops are sometimes called “tax exempt” cooperatives. This is incorrect. Section 521 is in the exempt section of the Code and during the early and middle 20th Century these types of co-ops were totally tax exempt. But today they are taxed just like other Subchapter T co-ops, except for the ability to claim the two extra deductions.

Forms Subchapter T Cooperatives Tax exempt Cooperatives file Form 990
IRS has released a new Form 1120-C to be filed for tax years ending on or after December 31, 2007 Tax exempt Cooperatives file Form 990 Non-exempt Utility Cooperatives file Form 1120 Distributions to patrons are reported on Form 1099-PATR

Worksheets - Vegepacker Cooperative
Net Margin - $50,000 Corporate tax rate is 15% on that income Half of the total net margin is allocated to patrons in the 15% bracket, half to patrons in the 25% bracket Two representative patrons each provide 8% of Vegepacker’s product - Patron A who is in the 15% bracket and Patron B in the 25% bracket Please turn to page 22 of your manual. We are now going to do an exercise designed to give you hands on experience with a simple cooperative tax planning model. This slide contains the facts we’ll be using in the exercise. While some of the pages have the numbers filled in, others have blank spaces. When we come to a page with blanks, I’ll give you a couple of minutes to compute the numbers that go in the blanks and then provide the proper entries.

Vegepacker Cooperative
Worksheets The $50,000 margin is placed into a tax paid reserve The $50,000 margin is distributed as qualified patronage refunds (20% in cash) The $50,000 margin is distributed as non-qualified patronage refunds These are the three options available to a cooperative for retaining some or all of its patronage-sourced earnings. We will examine the cash flow and tax consequences, for both the cooperative and its patrons, of implementing each option. It is up to the board of directors, usually after receiving a recommendation or set of choices from the staff and outside financial advisers, to decide which path to follow.

Example A: Total Tax Obligations (Tax Paid Reserve) Cooperative tax ($50,000 x .15) $7,500.00 Addition to equity $42,500 Patron tax, when equity is redeemed for cash ($21,250 x .15) $3,187.50 ($21,250 x .25) $5,312.50 TOTAL TAXES PAID $16,000.00 While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 42

Example B: Tax treatment, all $50,000 distributed as qualified patronage refunds (20% in cash, 80% as an allocation of retained equity) While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 43

Example B: Total Tax Obligations (Qualified Allocations) Cooperative tax ( $______ x .15) $ _________ Addition to equity $_________ Patron tax in total ($______ x .15) $ _________ ($______ x .25) $ _________ TOTAL TAXES PAID $ _________ While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 44

Example B: Total Tax Obligations (Qualified Allocations) Cooperative tax ( $ x .15) $ 0 Addition to equity $ 40,000 Patron tax in total ($ 25,000 x .15) $ 3,750 ($ 25,000 x .25) $ 6,250 TOTAL TAXES PAID $ 10,000 ANSWERS While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 45

Example B: Individual Patron Analysis Patron A: Individual refund allocation $ ,000 Cash received ($4,000 x .20) 800 Tax owed ($4,000 x .15) 600 Cash Flow $ While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 46

Example B: Individual Patron Analysis Patron B: Individual refund allocation $ ,000 Cash received ($______ x ____) _______ Tax owed ($______ x ) _______ Cash Flow $ _______ While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 47

Example B: Total Tax Obligations (Qualified Allocations) ANSWERS Patron B: Individual refund allocation $ 4,000 Cash received ($4,000 x .20) 800 Tax owed ($4,000 x .25) 1,000 Cash Flow $ (200) How do you think Patron B feels about receiving a patronage refund? What can be done about it? While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 48

Example C: Tax treatment, all $50,000 distributed as nonqualified patronage refunds (100% as an allocation of retained equity) While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 49

Example B: Total Tax Obligations (Non-Qualified Allocations) YEAR OF ISSUANCE Cooperative tax ( $______ x .15) $ _________ Addition to equity $_________ Patron tax in total ($______ x .15) $ _________ ($______ x .25) $ _________ TOTAL TAXES PAID $ _________ While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 50

Example B: Total Tax Obligations (Non-Qualified Allocations) ANSWERS YEAR OF ISSUANCE Cooperative tax ( $ 50,000 x .15) $ 7,500 Addition to equity $ 42,500 Patron tax in total ($ 0 x .15) $ 0 ($ 0 x .25) $ 0 TOTAL TAXES PAID $ 7,500 While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 51

Example C: Total Tax Obligations (Non-Qualified Allocations) YEAR OF REDEMPTION Cooperative tax ( $______ x .15) $ _________ Patron taxes in total ($______ x .15) $ _________ ($______ x .25) $ _________ TOTAL TAXES PAID $ _________ While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 52

Example C: Total Tax Obligations (Non-Qualified Allocations) ANSWERS YEAR OF REDEMPTION Cooperative tax ( $ - 50,000 x .15) $ -7,500 Patron taxes in total ($25,000 x .15) $ 3,750 ($25,000 x .25) $ 6,250 TOTAL TAXES PAID $ 10,000 While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 53

Example C: Individual Patron Analysis (Non-Qualified Allocations) Year of Issuance Patrons receive no cash and have no tax liability, so there is nothing to analyze While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 54

Example C: Individual Patron Analysis (Non-Qualified Allocations) YEAR OF REDEMPTION Patron A: Individual refund allocation $ 4,000 Cash received $ 4,000 Tax owed ($_____ x ) $_________ Cash Flow $_________ Patron B: Individual redemption payment $ 4,000 Cash received $_________ Tax owed ($_____ x ) $_________ While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 55

Example C: Individual Patron Analysis (Non-Qualified Allocations) ANSWERS YEAR OF REDEMPTION Patron A: Individual refund allocation $ 4,000 Cash received $ 4,000 Tax owed ( $4,000 x .15) $ 600 Cash Flow $ 3,400 Patron B: Individual redemption payment $ 4,000 Tax owed ( $4,000 x ) $ 1,000 Cash Flow $ 3,000 While this may seem like a test, I promise that no one will be grading you. For A and B, how would you record these transactions in the form of simple journal entries? C just requires a total. Please take a couple of seconds to complete the problem. Then I will provide the answers and take any questions. 56

Tax Summary Reserve Qualified Non-Qualified Co-op (Earned) $ 7,500
$ 7,500 $7,500 Co-op (Redeemed) -$7,500 Patrons (Allocated) $10,000 Patrons (Redeemed) $ 8,500 TOTAL $ 16,000 In summary, we see that the ultimate tax owed, whether qualified or nonqualified allocations are used, is the same. The cooperative has not paid a tax and the patrons have paid a single tax on their pro rata share of the earnings. The difference between the two options involves the timing of the tax obligations. And again, we see the value of the single tax treatment available to cooperatives under Subchapter T of the Code. Without Subchapter T, the IRS would wind up with $16,000 of the members’ money. Because of the single tax treatment available to cooperatives, the IRS only receives $10,000 of the members’ money.

Cooperative Taxation QUESTIONS 58

Basic Cooperative Taxation

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