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Understanding Accountable Plans: Definition, Benefits, and Implementation

Accountable Plans

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In an ever-evolving business landscape, corporations, especially S Corporations, are continually seeking strategies to optimize their tax positions. One particular strategy that has proven beneficial is the implementation of an Accountable Plan. This guide provides a comprehensive insight into Accountable Plans, their advantages, and how to effectively implement them.

Defining Accountable Plan

An Accountable Plan is a formal arrangement established by a business to reimburse employees for out-of-pocket business expenses. Such expenses could range from travel and meals to home office costs and mileage. The defining characteristic of an Accountable Plan is that the reimbursements are not considered taxable income for employees, thereby offering a significant tax advantage.

The Advantages of Accountable Plans

The benefits of implementing an Accountable Plan are twofold, offering distinct advantages for both employers and employees.

Benefits to Employers

The primary benefit for employers is the reduction in payroll taxes. Payments made under an Accountable Plan are not considered wages, meaning they are not subject to payroll taxes. This effectively transforms a deductible business expense into a non-taxable reimbursement, lowering the company's tax liability.

Benefits to Employees

For employees, the benefits are also substantial. Since reimbursements under an Accountable Plan are not treated as income, they are not subject to income taxes. This means employees can be compensated for their out-of-pocket business expenses without it impacting their personal tax situation.

The Proper Operation of an Accountable Plan

To qualify as an Accountable Plan, the Internal Revenue Service (IRS) stipulates that certain conditions must be met. These include:

Business Connection

The plan must only reimburse employees for expenses that are directly related to business activities. If an expense serves both personal and business purposes, only the business portion of the cost can be reimbursed.

Adequate Substantiation

Employees must provide sufficient documentation to verify the expenses incurred. This typically involves an account book, log, receipt, or credit card statement. Importantly, the proof must be specific enough to differentiate the types of expenses.

Return of Excess Reimbursement

If employees are given reimbursements that exceed the actual expenses incurred, they are required to return the surplus to the company within a specified timeframe. If they fail to do so, the excess may be treated as taxable income.

Eligible Expenses under Accountable Plan

The range of expenses that can be reimbursed under an Accountable Plan is quite broad, encompassing various categories of business-related costs. Some of the most common types of expenses include:

  • Home Office Expenses

  • Travel Expenses

  • Meals and Entertainment

  • Auto Expenses

  • Tools and Supplies

  • Training and Development Costs

  • Dues, Subscriptions, and Professional Licenses

Compliance Requirements for an Accountable Plan

While there's no formal requirement to put an Accountable Plan in writing, having a written policy in place is highly advantageous. This ensures clarity on the rules of the plan and provides a record of the company's compliance in the event of an IRS audit.

The written plan should ideally include:

  • A list of reimbursable expenses

  • A defined timeframe for employees to report expenses

  • The maximum reimbursable limit for each expense

  • Guidelines on how to calculate reimbursable expenses

  • The process for requesting reimbursement and the required documentation

  • A process outlining how employees can return excess reimbursements

Tax Implications of an Accountable Plan

One of the main attractions of an Accountable Plan is the favorable tax treatment it provides. For businesses, all reimbursed expenses are tax-deductible, reducing taxable income and thus tax liability. For employees, the reimbursements received are not considered taxable income, thereby reducing their personal tax burden.

However, it's worth noting that if a reimbursement plan fails to meet all the requirements of an Accountable Plan, the IRS will treat it as a "Non-Accountable Plan." In such cases, the reimbursements are considered taxable compensation to the employee and are subject to withholding and must be reported on the employee's W-2 form.

Accountable Plans in S Corporations

Accountable Plans can be particularly beneficial for S Corporations, where owners are often also employees of the business. These owner-employees tend to have higher out-of-pocket business expenses than non-owner-employees, and an Accountable Plan allows them to be reimbursed for these costs without it being treated as taxable income.


In conclusion, Accountable Plans can offer significant tax advantages for both businesses and employees. While the implementation process might seem complex, the benefits are substantial. By taking the time to understand and effectively implement an Accountable Plan, businesses can achieve a more favorable tax position, while also ensuring that employees are adequately compensated for their out-of-pocket business expenses.


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