Archive for October 22, 2015

What is Considered Unrelated Business Income?

shutterstock_130231046Non-profit organizations that have gross income of $1,000 or more from an unrelated trade or business are required to file Form 990-T with the IRS. But what is considered unrelated business income (UBI)? According to the IRS, for most organizations, an activity is an unrelated business, and therefore subject to unrelated business income tax (UBIT), if it meets the following three requirements.

  1. It is a trade or business;
  2. It is regularly carried on; and
  3. It is not substantially related to furthering the exempt purpose of the organization.

An example of possible UBI is a non-profit organization that regularly holds weddings or other events not related to the organization’s exempt purpose on their facilities. Another is a non-profit university that regularly charges the public for usage of a parking garage for unrelated activities. Note that there are a number of exclusions and exceptions to the general definition of UBI. Determining whether a certain activity is UBI is not usually black and white and requires some judgment and analysis. Annually, management should consider their current year operations to determine if there could possibly be any UBI. Management should seek help from their tax preparer for guidance. All management decisions should be supported and documented in writing. For more information and detail on UBI and examples and exceptions, please click on the following link to the IRS Publication 598.

 

Shannon Crowley Massachusetts CPAShannon Crowley is a manager in BlumShapiro’s Accounting and Auditing Department, based in Quincy, Massachusetts, Shannon oversees audit engagements and is responsible for engagement planning, staff supervision and coordination with client personnel to ensure successful completion of projects. Shannon has worked with clients in a variety of industries, including healthcare, higher education, non-profit, manufacturing and distribution.

Four Thresholds Massachusetts Non-Profits Should Be Aware Of

Non-profits are subjected to several regulatory requirements. Below are four thresholds of which that managers of Massachusetts non-profits should be aware:

iStock_000003856109_ExtraSmall1. Review vs. Audit: The Massachusetts Attorney General’s Office requires any charitable non-profit organizations, with gross support and revenue between $200,000 and $500,000 in the fiscal year to have reviewed financial statements, and any revenue over $500,000 in the fiscal year to have audited financial statements. Both the reviewed and audited statements are required to be submitted with the annual Massachusetts Form PC filing.

2. Single Audit Threshold: For fiscal years beginning on or after January 1, 2015, the Office of Management and Budget (OMB) requires a single audit if there are expenditures using federal funds of $750,000 or more in a single fiscal year. This is an increase from the prior threshold of $500,000. Management should keep in mind that the threshold relates to expenses incurred, not revenues received or earned. Also, spending of federal monies does not just include those received directly from the federal government, but also includes any pass-through federal monies received from other non-profits, states, or agencies.

3. Massachusetts Uniform Financial Statements and Independent Auditors’ Report (UFR) Filing: The Operational Services Division (OSD) requires human and social service organizations that deliver services to consumers in Massachusetts using state contracts to file an annual UFR or a UFR cover page and Exceptions/Exemption documentation.

4. 403(b) Plan Audit: The Federal Department of Labor (DOL) requires an audit for 403(b) plans with participant counts greater than 120.   Participant counts should include the following: (a) eligible employees at the beginning of the plan year (whether they participate in the plan or not); and, (b) participants who terminated and still have account balances. For 403(b) plans you can exclude participants who terminated prior to January 1, 2009.

The above are brief descriptions of the requirements and are not all inclusive. If you have any questions or would like further information on any of the requirements above, please contact us.

Shannon Crowley Massachusetts CPAShannon Crowley is a manager in BlumShapiro’s Accounting and Auditing Department, based in Quincy, Massachusetts, Shannon oversees audit engagements and is responsible for engagement planning, staff supervision and coordination with client personnel to ensure successful completion of projects. Shannon has worked with clients in a variety of industries, including healthcare, higher education, non-profit, manufacturing and distribution.

Revenue Recognition Step 3: Determine the Transaction Price

137299508The third step of the new revenue recognition standard is to determine the transaction price,  which is the amount of consideration to which an entity expects to be entitled and includes:

  1. An estimate of any variable consideration (i.e. amounts that vary due to rebates or bonuses) using either a probability weighted expected value or the most likely amount, whichever better predicts the amount of consideration to which the entity will be entitled.
  2. The effect of the time value of money, if there is a financing component that is significant to the contract.
  3. The fair value of any non-cash consideration.
  4. The effect of any consideration payable to the customer, such as vouchers and coupons.

The transaction price is generally not adjusted for credit risk. However, the transaction price is constrained because of variable consideration. This means that the standard limits the amount of variable consideration to the amount for which it is probable that a subsequent change in estimated variable consideration will not result in a significant revenue reversal.

This is a change from current accounting for revenue, as accounting for variable consideration is inconsistent across industries. Under current guidance, an organization does not include variable amounts in the transaction until the variability is resolved. The new standards give a single model whereby variable consideration (e.g., rebates, discounts, bonuses, right of return) will be included in the transaction price to the extent it is probable that a significant reversal in the amount of cumulative revenue recognized will not occur. This inclusion of variable consideration may accelerate the recognition of revenue compared to current standards.

Read other articles in our “Revenue Recognition” Series:

Hatch, MichelleMichelle Hatch is a partner in our Non-Profit Services Group. She oversees audit and accounting engagements for non-profit organizations, including independent schools, trade associations, health and human service organizations and art, cultural and membership organizations. Michelle is also a member of the Employee Benefit Assurance Group and oversees audits for 401(k), 403(b) and defined benefit retirement plans.