Accountable plan
accountable reimbursement plan / nonaccountable plan / employee expense reimbursement rules
An accountable plan is an employer's arrangement for reimbursing employees' business expenses that meets three IRS rules. Payments under it are not wages, so no income, Social Security, Medicare or FUTA tax applies. Payments under a plan that misses the rules are taxed as wages.
IRS Publication 15, the employer's tax guide, sets three rules. Employees must have paid or incurred allowable expenses while working for the business. They must substantiate those expenses within a reasonable period of time. And they must return any amount beyond the substantiated expenses within a reasonable period of time.
Meeting all three changes the tax. Amounts paid under an accountable plan are not wages and are not subject to income, Social Security, Medicare or FUTA taxes. Under a nonaccountable plan the same payments are supplemental wages, taxed like pay.
Publication 463 gives the deadlines that always count as reasonable. An advance comes within 30 days of the expense. The employee accounts for expenses within 60 days after paying them. Any excess comes back within 120 days after the expense. Accounting means a record made at or near the time, with documentary evidence such as receipts.
Two setups fail by design. Paying a flat amount as a reimbursement that would otherwise have been paid as wages is treated as a nonaccountable plan. So is repaying expenses by reducing the wages reported.
In practice
A contractor gives each of its three estimators $400 a month toward mileage and phone costs, with no receipts asked for and nothing ever returned. Under Publication 15 that is a nonaccountable plan, so the $14,400 a year is wages and payroll taxes apply. Requiring mileage logs and phone bills within 60 days, and repaying only what they show, would meet the accountable plan rules. The figures are a worked example.
Not the same as
- Nonaccountable plan
- A nonaccountable plan is any reimbursement or allowance arrangement that misses one or more of the three rules. Its payments are wages, subject to income, Social Security, Medicare and FUTA taxes.
Why it matters to you
A monthly allowance with no paperwork looks like a reimbursement and is taxed like pay. Writing down the three rules, and holding employees to the receipt and return deadlines, keeps genuine expense repayments out of payroll taxes for the business and income tax for the employee.
What to ask or check
- 01Does the reimbursement policy require receipts or logs, and by when?
- 02What happens to money advanced to an employee and never spent on business?
- 03Are any flat allowances paid whether or not the employee has expenses?
What people get wrong
That calling a payment a reimbursement keeps it out of payroll taxes. The IRS treats it as wages unless the arrangement requires a business connection, substantiation within a reasonable time, and return of any excess.