Federal Tax Business Interest Expense Limitations Under IRC Section 163(j) Applicable to Cooperatives

Date: Tuesday, June 18, 2024
Time: 02:00 PM ET / 01:00 PM CT / 12:00 PM MT / 11:00 AM PT [Prevailing Time]
Presenter: David Antoni, CPA, Tax Managing Director, Moss Adams
Moderator: Wayne Sine, CPA, Education Director, National Society of Accountant for Cooperatives
Learning Objectives:
1) Gain an overview understanding of the limitation provisions on section 163(j) on business interest expense of cooperative organizations.
2) Understanding of the availability for specified agricultural cooperatives on the farming business election out of section 163(j) and associated implications of the election.
3) Understanding of considerations for patrons and cooperatives of section 163(j) relative to planning for utilization of disallowed business expense carryovers and patronage dividends received as price adjustment reductions in interest expense.
Field of Study: Taxes
Program Level: Basic
CPE Credit: 1 Credit Hour
Delivery Method: Group Internet-based
Prerequisite(s): No advanced preparation or prerequisites are required for this course.
  Order Recording

Course Description

This session will provide an overview of the specific section 163(j) provisions applicable to Subchapter T cooperatives, an overview of the specified agricultural cooperative provisions for the farming business irrevocable election out of section 163(j) and effects on required adoption of ADS depreciation for property with a recovery period of 10 years or more. This session will also discuss implications of making the farming business election in event the cooperative has disallowed business expense carryover into the year of the election and planning considerations for utilization of the business expense carryover. In addition, this session will also discuss with respect to patrons borrowing on a patronage basis from cooperative lenders and impacts and planning for patronage dividends received from the cooperative lender as an effective price adjustment reduction in interest expense.

Presenter and Moderator Bios

Presenter: David Antoni, CPA, Tax Managing Director, Moss Adams

Dave Antoni has worked in professional tax accounting since 1986 serving domestic and multinational companies. Dave’s areas of industry focus include life science, food and beverage, cooperatives, consumer and industrial markets, retail, technology, and insurance. Prior to joining Moss Adams, Dave worked for 37 years with a Big Four firm.

Dave serves as a National Tax Managing Director providing technical expertise in ASC 740, taxation of cooperatives and insurance. He has extensive experience with inbound and outbound multi-national companies and coordinates service delivery with client service teams of specialists including accounting methods and credit services, compensation and benefits, international tax, M&A, state and local tax, valuations, and transfer pricing services. Dave is the Past President of the National Society of Accountants for Cooperatives (NSAC). 

Moderator: Wayne Sine, CPA, Education Director, National Society of Accountant for Cooperatives

After retiring as Tax Director for Southern States Cooperative, Wayne Sine was asked to serve as Education Director for NSAC. He has been a long-time and active member of NSAC, having served as past President of the Atlantic Chapter and past Chair of the Tax Committee. In addition to his work with NSAC, Wayne has served on the Legal, Tax, and Accounting (LTA) Committee of the National Council of Farmer Cooperatives, Chaired the Tax Committees for both the Virginia Chamber of Commerce and the Virginia Manufacturers Association, served on the Tax Policy Committee of the Virginia Society of CPAs, and served as past Region Vice President for the Tax Executives Institute.

Cost
Free for NSAC Members / $56.00 for Non-Members

Delivery System

• All programs are delivered using the Zoom platform.
• Confirmations will include log-in instructions.
• Participants are able to participate using any device with an Internet connect (if the device does not have speakers, the participant can also dial-in) or they can participate with audio only by dialing in.
• All registrants will receive a link to the CLN’s recording by email within 48 business hours of event’s conclusion.
• There will be assistance available to help with technical and connectivity issues up to 10 minutes prior to the start of the presentation.

Registration

All registration is done on-line and each guest must provide their name and email address to participate. All NSAC members may register for free. Non-members may register for a nominal fee.

Refund Policy

NSAC will not issue refunds for CLNs. If a registrant is unable to participate in the CLN and provides notification to info@nsacoop.org 48 hours prior to the session, a credit will be provided for a future CLN. Alert the NSAC staff member monitoring the CLN if technical difficulties are encountered and technical support will be provided to eliminate problems with future CLNs.

Additional Information

Live participation is required for CPE credit and polling questions must be answered to document your active participation. All registrants will receive an email following the session with links to the slides and/or handouts, and a link to the CLN recording (unless otherwise stated). If you are unable to participate in the live session, you can still watch the recorded session, but you will not be eligible for CPE credits. Those eligible for credits will receive their certificate by email with 7 business days.

For more information regarding NSAC CLNs or administrative policies such as complaint and refund, contact the NSAC Headquarters, 7946 Clyo Road, Suite A, Centerville, OH 45459, 937-222-6707, or info@nsacoop.org.