Implications of book versus tax based patronage in agricultural cooperatives

Abstract

Cooperative businesses are taxed under Sub-Chapter T of the IRS tax code. Under that provision, cooperative businesses are allowed to deduct profits distributed to their member-owners (termed patronage dividends). Any income remaining after patronage distributions is taxed at the regular corporate rate. Patronage calculations can be based on either "book" net income following the accrual method of Generally Accepted Accounting Principles (GAAP) or on a tax basis reflecting a cooperative's IRS calculations. The difference between the two income calculations are referred to as "Book Tax Differences" (BTD). The two alternative methods for income calculation can lead to both permanent and temporary BTD. Permeant BTD are created when an income or expense is recorded on a book basis which will never be recognized on a tax basis or vice versa. A common permanent BTD in an agricultural cooperative would be the Section 199A deduction. Temporary BTDs occur when timing of income or expense recognition varies between book and tax methods. Common temporary BTD in agricultural cooperatives include accelerated or bonus depreciation and the receipt of nonqualified equity patronage from regional cooperatives. BTDs are particularly important for cooperative businesses because profits are shifted over time. The members doing business and receiving patronage in future years may be different from those patronizing the cooperative in the year the BTD was created. Because of that potential effect there is a clear need for research on the implications of book and tax based patronage on agricultural cooperatives and their members.