Choosing or changing a method for tax purposes.

Cash or Accrual? By Robert Jennings.

With the release of revenue procedure 2000-22, the IRS provided small businesses with much needed guidance on choosing or changing their accounting methods for tax purposes. This article summarizes the rules that apply when businesses must pick an accounting method and examines some of the other factors that influence their decision.

THE SALES TEST

Revenue procedure 2000-22 allows any company that meets a sales test to use the cash method of accounting for tax purposes. This includes sole proprietors, partnerships, S corporations and regular corporations. If a taxpayer meets the sales test, it no longer matters whether it is selling merchandise that is a "material income-producing factor" (discussed below).

To compute the sales test, a company averages revenue from the last three years. If the average is less than the $1 million threshold, the cash method is always allowed (but not required). For purposes of this test gross receipts include most normal items, such as sales revenue, services, interest, dividends, rents, royalties and the like, but not sales tax the taxpayer collects.

Companies that are part of controlled groups must combine receipts for all entities included in the group to determine if they meet the $1 million test. Short years require an annualization adjustment. For taxpayers in business less than three years, the average is computed using revenue from only the years in existence.

The revenue procedure originally had included one other requirement: the conformity rule. Except in isolated circumstances, such as on a one-time basis to obtain a bank loan, the taxpayer was required to use the cash method of accounting for financial statements prepared for any party - management, investors or creditors - and for any year ending after December 16, 2000. This requirement would have undoubtedly caused problems when an accountant prepared accrual basis financial statements for a small business client. The IRS remedied the problem early this year in revenue procedure 2001-10, which removed the conformity requirement but re-emphasized the need for adequate books and record,- as required by IRC section 446 and reminded companies to maintain a reconciliation between book and tax income.


PASS/FAIL

Revenue procedure 2000-22 does not apply to companies that fail the $1 million average revenue test. For these entities, determining whether to use the cash or the accrual method is based on two issues: the material income-producing factor test and the type of entity. Generally companies that sell merchandise must use the accrual method for purchases and sales. This rule is more properly known, under Treasury regulations section 1.446-1, as the material

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