IRS Accountable Plan: Ensuring Compliance and Maximizing Deductions


An IRS accountable plan is a reimbursement system for business expenses that adhere to specific rules set by the Internal Revenue Service (IRS). These plans allow employees to receive reimbursement for work-related expenses without having the payments considered taxable income. Employers benefit from an accountable plan by being able to deduct reimbursed employee expenses as a business expenditure on their taxes.

Accountable plans are governed by the Internal Revenue Code Section 62(c) to ensure compliance with federal regulations. To qualify as an accountable plan, the reimbursement arrangement must meet three core requirements: a business connection, substantiation, and returning excess payments. By meeting these accountability requirements, the accountable plan can offer several tax advantages for both employers and employees.

Key Takeaways

  • Accountable plans offer tax advantages by allowing employees to receive reimbursements for work-related expenses without adding the payment to taxable income.
  • The IRS sets specific rules for accountable plans under Section 62(c) of the Internal Revenue Code, with three main requirements: business connection, substantiation, and returning excess payments.
  • Proper documentation and recordkeeping are essential, along with the understanding of differences between accountable and non-accountable plans, to ensure compliance with IRS regulations and maximize benefits for employers and employees.

Understanding Accountable Plans

Definition of Accountable Plan

An accountable plan is a system established by a business to reimburse employees for work-related expenses without making the reimbursement subject to taxes. It is based on the guidelines provided by the Internal Revenue Service (IRS) in Section 62 (c) of the Internal Revenue Code. This plan serves as a method to compensate employees for out-of-pocket business-related costs incurred during the course of their work.

Benefits of an Accountable Plan

There are several benefits associated with implementing an accountable plan, both for employers and employees:

  1. Non-taxable reimbursements: The primary benefit is that reimbursements made under an accountable plan are not considered part of an employee’s taxable income. This means that they won’t have to pay taxes on these amounts, reducing their overall tax burden.
  2. Lower gross income: Since the reimbursements are non-taxable, they are also excluded from an employee’s gross income, potentially keeping them in a lower tax bracket.
  3. Business expense deductions: Employers can still claim deductions on their tax returns for business expenses reimbursed through an accountable plan, as these expenses are still considered legitimate business costs.

Key Principles of Accountable Plans

For an accountable plan to be valid, it must comply with three main principles outlined by the IRS:

  1. Business connection: The expenses being reimbursed must have a direct business connection. They should arise from the employee’s performance of services as an employee.
  2. Adequate accounting: The expenses must be substantiated within a reasonable period, typically within 60 days of incurring the expense. This involves providing documentation, such as receipts or invoices, that verifies the amount, time, place, and business purpose of the expense.
  3. Return of excess reimbursements: Employees must return any reimbursed amounts that exceed the actual expenses within a reasonable period, usually 120 days after receiving the excess.

Following these principles ensures that an accountable plan stays compliant with IRS rules and benefits both employers and employees by simplifying the reimbursement process and reducing tax liabilities.

Components of an Accountable Plan

Valid Business Connection

A crucial component of an accountable plan is establishing a valid business connection. This means that all reimbursements made to employees under the plan must exclusively cover expenses with a clear and direct relation to the business. Common examples of such expenses include travel, mileage, meals, and lodging. The expenses must be incurred during the ordinary course of the employee’s job duties. The accountable plan must specifically state the business purposes for each type of reimbursement.

Adequate Substantiation Requirements

Proper documentation is necessary for all employee expenses. Under an accountable plan, employees must provide adequate substantiation for their expenses within a reasonable period. This may include presenting receipts, invoices, or other forms of proof for the business expense. Employers should establish clear guidelines for the types of documentation they accept to ensure that employees meet the substantiation requirements.

Moreover, employers may provide an allowance system for certain expenses, such as mileage. In this scenario, an employee may receive a predetermined rate for every business mile traveled and is required to maintain a mileage log to substantiate the claim.

Expense Type Documentation Requirement
Travel Itinerary, receipts
Mileage Mileage log
Meals Receipts, business purpose
Lodging Receipts, business purpose

Returning Excess Amounts

The accountable plan must include provisions for the return of excess amounts by employees. In cases where the reimbursement exceeds the employee’s actual expenses, the employee must return the excess amount to the employer within a reasonable period. Failure to do so may lead the IRS to consider the entire reimbursement as non-accountable, which may result in extra taxation for both the employer and the employee.

In summary, an accountable plan must have a valid business connection, require adequate substantiation, and include provisions for returning excess amounts. By adhering to these guidelines, employers can foster compliant and organized expense reimbursement processes.

Proper Documentation and Recordkeeping

Receipts and Records

It is essential for employees and employers to maintain accurate records and receipts related to business expenses incurred. Good records provide the foundation for an IRS accountable plan, ensuring that reimbursements for business expenses are made in a non-taxable manner. Participants should keep receipts for all expenses, especially for meals, accommodations, and transportation. When submitting an expense report, include the receipts and a detailed description of the expense, along with the business purpose, date, and location.

It is recommended to use a computer or a recordkeeping application to keep track of expenses and receipts electronically. This approach not only facilitates the organization but also reduces the risk of losing physical receipts.

Timely Submission of Expenses

One of the key components of an accountable plan is the timely submission of expenses. Employees should submit their expenses within a reasonable period, as defined by the IRS, typically within 60 days of incurring the business expense. Employers should also establish clear guidelines and deadlines for expense submission, as delays in submission can result in failure to comply with an accountable plan.

Record Retention Requirements

Retaining accurate records of employee reimbursements and business expenses is crucial for maintaining an accountable plan. The IRS generally requires businesses to keep records and documentation related to business expenses for a minimum of three years. However, it is advisable to maintain records for a more extended period, such as seven years, in case of audits or unexpected issues.

Careful documentation and recordkeeping practices, including maintaining all receipts, computer-based expense tracking, and timely submission of expenses, are integral to ensuring full IRS compliance with an accountable plan. By following these guidelines, businesses can successfully manage employee reimbursements and business expenses while adhering to tax regulations.

Differences Between Accountable and Nonaccountable Plans

Treatment of Reimbursements

In an accountable plan, an employer reimburses employees for work-related expenses that meet certain requirements outlined in Section 62(c) of the Internal Revenue Code. Reimbursements are non-taxable only when three conditions are met:

  1. There is a business connection for the expenses.
  2. Expenses are substantiated within a reasonable period.
  3. Any excess reimbursement must be returned to the employer within a reasonable period.

A nonaccountable plan is a reimbursement arrangement that does not meet all three requirements of an accountable plan. In this case, reimbursements are considered taxable income and there is no requirement to return excess reimbursement.

Tax Consequences

For accountable plans:

  • Reimbursements are not included in an employee’s taxable income.
  • Reimbursements are not subject to income tax or Social Security, Medicare, and federal unemployment (FUTA) taxes.
  • Employees do not report these reimbursements on their tax returns as they are not considered income.

For nonaccountable plans:

  • Reimbursements are included in the employee’s taxable income and are subject to income tax, Social Security, Medicare, and FUTA taxes.
  • Reimbursements are reported on the employee’s W-2 form as part of their wages.
  • Employees can potentially claim certain work-related expenses as itemized deductions on their tax returns, but these deductions may be limited.

It is essential for employers and employees to understand the difference between accountable and nonaccountable plans to ensure proper reporting and compliance with the Internal Revenue Service. Clear documentation of expenses and timely management of reimbursements will help maintain an accountable plan and avoid unnecessary tax consequences.

Reporting Requirements Under an Accountable Plan

Reimbursements on W-2

Under an IRS accountable plan, employees receive reimbursements for their business-related expenses without having to report them as income on their tax returns. Employers should not include accountable plan reimbursements on the employee’s W-2 form, as these reimbursements are not subject to income or employment taxes.

The employee receives these reimbursements tax-free, provided they meet certain conditions. The three requirements for reimbursements under an accountable plan are:

  1. Business connection: Expenses must be incurred or paid in connection with the employee’s performance of service.
  2. Substantiation: Employees must adequately account for these expenses to their employer within a reasonable period.
  3. Return of excess: Employees must return any excess reimbursements, the amount not spent on approved expenses, within a reasonable period.

Deductible Business Expenses on Tax Forms

If an employee incurs business expenses that were not reimbursed by an accountable plan, they may be able to deduct these expenses on their tax forms. Unreimbursed employee business expenses are generally deducted on Schedule 1 (Form 1040) as an adjustment to income.

Keep in mind that only business-related expenses are deductible. Examples of deductible business expenses may include:

  • Home office expenses
  • Travel expenses and meal expenses (actual or per diem rates)
  • Work-related supplies and equipment

It is crucial for employees to maintain accurate records of their business expenses, as the IRS may request substantiation for any deductions claimed on the income tax return.

In summary, when participating in an accountable plan, employees benefit from receiving reimbursements tax-free and not having to report them as income. Employers should not include reimbursements on the employee’s W-2, and employees should only claim deductions on their tax forms for unreimbursed, business-related expenses.

Special Considerations for Different Types of Expenses

In this section, we will discuss special considerations for different types of expenses under IRS accountable plans. Remember, it is crucial for businesses to understand these rules to ensure they comply with regulations and maintain valid accountable plans.

Travel and Lodging

When reimbursing employees for travel and lodging expenses, companies must ensure that these costs are both ordinary and necessary for the business. The general rule is that employees should provide substantiation for these expenses, including receipts, dates, and locations of travel. It’s also important to remember that the accommodation should be reasonable, meaning extravagant hotels should be avoided.

Meals and Entertainment

For meals and entertainment expenses, the IRS has some specific rules. In general, meals during business travel can be reimbursed as part of an accountable plan. However, the Tax Cuts and Jobs Act (TCJA) has modified the treatment of entertainment expenses. Starting from January 1, 2018, companies can no longer reimburse entertainment, recreation, or amusement expenses, such as tickets to sporting events or theater shows.

Transportation and Mileage

Regarding transportation and mileage, employees using their vehicles for business-related activities can be reimbursed as long as they provide proper substantiation. The IRS provides a standard mileage rate which businesses can use to calculate the reimbursement. This rate changes annually, and for the year 2024, the standard mileage rate is ___ cents per mile for business use. Employees should provide records of the miles driven, along with the purpose and dates of the trips.

Equipment and Supply Purchases

Finally, equipment and supply purchases made by employees can be reimbursed under accountable plans, provided they also meet the plan requirements. The items purchased should be directly related to the employee’s job, and the employees must provide documentation (receipts) to substantiate the expense. Examples of equipment and supplies include tools, office supplies, and electronic devices for work purposes.

Accountable Plan Rules for Various Business Structures

When implementing IRS accountable plans, it is crucial to understand the different requirements and provisions that apply to various business structures. This section will discuss the rules for corporations, partnerships and LLCs, and sole proprietors and self-employed individuals.


In a corporation, reimbursements and allowances made to employees under an accountable plan are not considered part of their wages, so they are exempt from payroll taxes and income taxes. To meet the IRS requirements, a corporation’s accountable plan must adhere to the following:

  • Expenses must have a business connection
  • Expenses must be substantiated within a reasonable period (usually 60 days)
  • Employees must return any excess reimbursements within a reasonable period (usually 120 days)

These requirements ensure the expenses are solely for business purposes and prevent any misuse of funds.

Partnerships and LLCs

Partnerships and LLCs follow similar rules as corporations regarding accountable plans. To maintain an accountable plan, partnerships and LLCs must ensure:

  • Business-related reimbursements are only allocated to partners or members
  • The plan meets the same business-connection, substantiation, and excess reimbursement requirements as described for corporations

It is worth noting that in partnerships and LLCs, reimbursements to employees other than partners or members are treated as wages subject to employment taxes, unless they are given under an accountable plan that meets the IRS criteria.

Sole Proprietors and Self-Employed

Sole proprietors and self-employed individuals can also establish accountable plans for their employees. In this case, reimbursements made under the plan are not subject to employment taxes and are deductible as business expenses.

To qualify as an accountable plan, sole proprietors and self-employed individuals must meet the following conditions:

  • There must be a business connection for the expenses
  • Expenses must be substantiated within a reasonable period
  • Any excess reimbursements must be returned within a reasonable period

Overall, different business structures share similar IRS accountable plan requirements intended to encourage responsible spending of funds on business-related expenses and reduce the tax burden for both employees and employers.

Implementing an Accountable Plan

Steps to Establish an Accountable Plan

An accountable plan is a method that employers can adopt to reimburse employees for work-related expenses in a non-taxable manner. Here are the steps to establish an accountable plan:

  1. Develop a written plan: Create a detailed, written plan outlining the rules and processes for reimbursing employees. This plan should clearly state the purpose and terms of the reimbursement policy.
  2. Ensure business connection: The expenses that are reimbursed must be directly related to the employer’s business. For example, if an employee needs to spend on postage in the line of duty, this can be reimbursed under an accountable plan.
  3. Adopt IRS rules for substantiation: Employees must provide appropriate documentation to support their expenses, as per the regulations specified by the Internal Revenue Service (IRS). This could include receipts, invoices, or other detailed information.
  4. Return unspent funds: If an employee receives more reimbursement than the actual expense incurred, they must return the excess amount to the employer within a reasonable period.

Maintaining Compliance with IRS Regulations

To ensure your accountable plan stays compliant with the IRS rules, it is crucial to follow the guidelines under Section 62 (c) of the Internal Revenue Code.

  • Regularly review and update the plan: Revisit the written plan periodically and make necessary amendments to stay current with any changes in IRS regulations.
  • Ensure proper documentation: Encourage employees to maintain records of their expenses and keep copies of these documents, such as photographs of missing children, for reference in case of an audit.
  • Audit reimbursements: Conduct internal audits to confirm that reimbursements are made in accordance with the accountable plan rules and substantiation requirements.

By following these steps and adhering to the IRS regulations, employers can implement an accountable plan that allows them to reimburse employees for work-related expenses in a tax-efficient manner while maintaining compliance with the Internal Revenue Service.

Frequently Asked Questions

What are the defining criteria for an IRS accountable plan?

An IRS accountable plan is a reimbursement arrangement between an employer and an employee that adheres to specific guidelines. To qualify as an accountable plan, the plan must meet three criteria:

  1. There must be a business purpose for the expense.
  2. Employees must substantiate their expenses with records and receipts within a reasonable time period.
  3. Employees must return any excess reimbursements within a reasonable time period.

How does an accountable plan differ from a non-accountable plan?

The main difference between accountable and non-accountable plans lies in the tax treatment of reimbursements. In an accountable plan, the reimbursements are tax-free and not reported on an employee’s W-2 form. In a non-accountable plan, the employees’ reimbursements are treated as taxable income and are subject to withholding taxes and reported on their W-2 forms.

What are the necessary time frames for expense reimbursements under an IRS accountable plan?

The IRS does not provide a specific time frame for substantiating expenses and returning excess reimbursements. However, they define a “reasonable time period” based on the specific facts and circumstances. A general guideline is that employees should substantiate expenses within 60 days after the expense is incurred, and excess reimbursements should be returned within 120 days after the expense was paid or incurred.

How should an accountable plan be reflected in W-2 forms, if at all?

Reimbursements made under an accountable plan are not taxable and should not be included as wages or compensation on an employee’s W-2 form. In contrast, reimbursements made under a non-accountable plan should be reported as wages and be subject to withholding taxes.

Can independent contractors utilize accountable plans, and if so, under what conditions?

Accountable plans are typically designed for employee-employer relationships and do not directly apply to independent contractors. However, independent contractors can deduct their legitimate business expenses on their income tax returns, reducing their taxable income in a similar way to employees under an accountable plan.

What changes have been made to the IRS accountable plan guidelines for the 2023 tax year?

No specific changes to the IRS accountable plan guidelines have been identified for the 2023 tax year in the provided search results. It is crucial to periodically review the latest IRS publications and guidelines to stay informed about possible changes and updates to the regulations.