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

CPE: 1 Credit Hours

Join our upcoming webinar on June 18th to gain valuable insights into the specific Section 163(j) provisions applicable to Subchapter T cooperatives. This 60-minute Zoom presented by David Antoni, CPA, Tax Managing Director at Moss Adams 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 the implications of making the farming business election in the event the cooperative has disallowed business expense carryover into the year of the election and planning considerations for utilization of the business expense carryover. Dave will dive into a discussion 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.

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.

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.