Processing and Marketing Cooperatives Provide An Extra Deduction

One quick note before we dive into the regular part of this post. We continue to get lots of emails and comments regarding the calculation of the Section 199A deduction for patrons who are under the threshold. IMPORTANT – You have to do the cooperative “reduction” calculation no matter your income level. This means if you pay wages, you will have a reduction in your Section 199A deduction, however, if you have no other sources of income, it is likely that the ordinary taxable income limit will be lower any way. Now for the post.

We have gotten some feedback on our last post. For 2018, there is a transition adjustment that all patrons who deal with a cooperative will need to compute. This adjustment in some cases will decrease your Section 199A deduction for the year and in many cases, it will actually reduce your Section 199A loss carryover to the following year. This year many farmers will have a tax loss. Normally, you have to carry forward this tax loss to 2019 and reduce your Qualified Business Income (QBI) calculations for that following year. However, for losses that occur prior to the fiscal year-end of the cooperative for 2018, that will reduce your loss carryover. As an example:

Assume a farmer has a net farm loss for 2018 of $250,000. 60% of that farm loss was attributable to receipts from a cooperative before the fiscal year-end. If the farmer had no cooperative receipts, the QBI loss carryover to 2019 would be $250,000. Instead, the loss carryover is only $100,000 due to the cooperative payments received before the fiscal year-end.

Additionally, cooperatives typically pass-through a DPAD deduction to the patron. Many of these cooperatives did an advance notification of this DPAD in 2017 and the farmer was able to deduct it then. For 2018, many other cooperatives (especially processing cooperatives) will pass-out a large DPAD in 2018 and in many cases, this deduction will be close to 3-7% of gross sales for most processing cooperatives.

Therefore, for farmers who deal with a processing cooperative in 2018, they are still likely to get a DPAD from the processing cooperative (although this may have shown up in 2017) and if your farm showed a loss for 2018, by dealing with a cooperative, your loss carryover will be reduced.

For 2019, all calendar year farmers should only have to calculate two buckets of income. One bucket for cooperative receipts and one bucket for all other receipts.

But 2018 still requires three buckets and this should be the most complicated year of the calculations.

  • Principal
  • CliftonLarsonAllen
  • Walla Walla, Washington
  • 509-823-2920

Paul Neiffer is a certified public accountant and business advisor specializing in income taxation, accounting services, and succession planning for farmers and agribusiness processors. Paul is a principal with CliftonLarsonAllen in Walla Walla, Washington, as well as a regular speaker at national conferences and contributor at agweb.com. Raised on a farm in central Washington, he has been immersed in the ag industry his entire life, including the last 30 years professionally. Paul and his wife purchase an 180 acre ranch in 2016 and enjoy keeping it full of animals.

Comments

How do wages and 9% of QBI related to cooperative operations affect the calculation of QBI for the bucket of income from the cooperative’s 2018 fiscal year when there is a farm loss. In your example above, is the $100,000 loss carryover still $100,000 if the farmer paid W-2 wages of $10,000? If the farmer paid wages of $50,000?

Hi Paul,
If I have 2 “buckets” of farm income – one of grain sold prior to the fiscal year end which makes up 40% and one after the fiscal year end which makes up 60%, I understand I only deduct 60% of the SE tax, but do I also only deduct 60% of the SE health insurance, since the other 40% is allocable to non-qualified income?

Similar to Andy’s question – If the co-op 1099s received this year do not show any per unit retains and they do not pass out a DPAD then how do I know as a tax preparer what was done on the co-op side. I have 1099s that show patronage dividends only. Based on that information how do I make adjustments to the Section 199A deduction?

Thank you Paul for your insights on the new law as it pertains to farmers. Can you point me to anywhere besides the instructions for Form 8903 that states the farmer’s QBI amount excludes payments received from a cooperative prior to it’s fiscal year-end? I understand the implications in the 8903 instructions but would like to back it up with something more. Thanks again.

Regarding transition rule for farmers: The definition of qualified payments references Section 1385(a)(1) and section 1385(a)(3). 1385(a)(1) says that patronage dividends must be considered for the transition rule. Section 1385(a)(3) says that per-unit retain allocation paid in qualified per unit retain certificates must be considered for the transition rule.

If a grain farmer deals with a co-op and does not receive any “qualified certificates” doesn’t that allow him to avoid the transition rule and thus the calculation of QBID does not exclude co-op payments under the transition rule?

Paul,

Thanks so much for your blog! Regarding the “grain glitch” and the 9% reduction much has been said about the cooperatives distributing DPAD in December of 2017 or perhaps even in 2018. This has led to much confusion within my firm….what if the cooperative that my client does business with did NOT pass out any DPAD in 2017 or 2018? If that is the case does my client still have three buckets or does he now only have two. Secondly, if he got no DPAD does he still have to reduce the coop sales by 9% or does he in fact now only have ONE BUCKET?

This new law is so confusing…thanks for your input!!

Color us confused in West Texas.