Instructions For Form 990-C - Farmers' Cooperative Association Income Tax Return - 2001 Page 15

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Other property (except nonqualified
1. Out of earnings not from business
Line 1. Enter the amount actually or
written notices of allocation).
done with or for patrons;
constructively paid as dividends during
A written notice of allocation means:
2. Out of earnings from business done
the tax year on:
Any capital stock,
with or for other patrons to whom no
Common stock (whether voting or
Revolving fund certificate,
amounts or smaller amounts are paid for
nonvoting),
Retain certificate,
substantially identical transactions;
Preferred stock,
Certificate of indebtedness,
3. To redeem capital stock,
Capital retain certificates,
Letter of advice, or
certificates of indebtedness, revolving
Revolving fund certificates,
Other written notice, which states the
fund certificates, retain certificates, letters
Letters of advice, or
dollar amount allocated to the patron by
of advice, or other similar documents; or
Other documentary evidence of a
the cooperative and the part, if any, which
4. Without reference to the net
proprietary interest in the cooperative
is a patronage dividend.
earnings of the cooperative organization
association.
In general, a qualified written notice
from business done with or for its patrons.
See Regulations section 1.1382-3(b)
of allocation is a written notice of
for more information.
allocation that is:
Line 2. Enter amounts paid on a
Paid as part of a patronage dividend in
Schedule J
patronage basis to patrons from
money or by qualified check equal to at
nonpatronage income. Payment may be
least 20% of the patronage dividend and
Tax Computation
in:
One of the following conditions is met:
Money,
Lines 1 and 2
1. The patron must have at least 90
Qualified written notices of allocation,
days from the date the written notice of
or
Members of a controlled group. A
allocation is paid to redeem it in cash,
Other property (except nonqualified
member of a controlled group, as defined
and must receive written notice of the
written notices of allocation).
in section 1563, must check the box on
right of redemption at the time the patron
The amounts must be paid during the
line 1 and complete lines 2a and 2b of
receives the allocation; or
payment period that begins on the first
Schedule J.
2. The patron must agree to have the
day of the tax year and ends on the 15th
Line 2a. Members of a controlled group
allocation treated as constructively
day of the 9th month after the end of the
are entitled to share one $50,000, one
received and reinvested in the
tax year in which the income was earned.
$25,000, and one $9,925,000 taxable
cooperative. See section 1388(c)(2) and
Nonpatronage income includes
income bracket amount (in that order) on
related regulations for information on how
incidental income from sources not
line 2a.
the consent must be made.
directly related to:
When a controlled group adopts or
Marketing,
If a written notice of allocation does not
later amends an apportionment plan,
Purchasing,
qualify, no deduction is allowable at the
each member must attach to its tax return
Service activities of the cooperative
time it is issued. However, the
a copy of its consent to this plan.
(such as income from the lease of
cooperative is entitled to a deduction or
The copy (or an attached statement)
premises, investments, or from the sale or
refund of tax when the nonqualified
must show the part of the amount in each
exchange of capital assets), or
written notice of allocation is finally
taxable income bracket apportioned to
Income from business done with or for
redeemed, if that notice was paid as a
that member. See Regulations section
the U.S. Government, or any of its
patronage dividend during the payment
1.1561-3(b) for other requirements and
agencies.
period for the tax year during which the
for the time and manner of making the
See Patronage dividends below for a
patronage occurred. The deduction or
consent.
definition of “qualified written notice of
refund is allowed, but only to the extent
allocation.” See section 1382(c)(2)(B) for
that amounts paid to redeem the
Equal apportionment plan. If no
deductibility of amounts paid in
nonqualified written notice of allocation
apportionment plan is adopted, members
redemption of nonqualified written notices
are paid in money or other property (other
of a controlled group must divide the
of allocation.
than written notices of allocation). They
amount in each taxable income bracket
cannot be more than the stated dollar
equally among themselves. For example,
Line 3. To be deductible, patronage
amounts of the nonqualified written notice
Controlled Group AB consists of
dividends must be paid during the
of allocation. See section 1382(b) and
Cooperative A and Cooperative B. They
payment period that begins on the first
related regulations.
do not elect an apportionment plan.
day of the tax year in which the patronage
Therefore, each cooperative is entitled to:
occurs and ends on the 15th day of the
See Rev. Rul. 81-103, 1981-1 C.B.
$25,000 (one-half of $50,000) on line
9th month after the end of that tax year.
447, for the redemption of nonqualified
2a(1),
See sections 1382(e) and (f) for
written notices of allocation issued to
$12,500 (one-half of $25,000) on line
special rules for the time when patronage
patrons by a payment of cash and a
2a(2), and
occurs if products are marketed under a
crediting of accounts receivable due from
$4,962,500 (one-half of $9,925,000) on
pooling arrangement, or if earnings are
patrons.
line 2a(3).
includible in the gross income of the
Note. See section 1383 for special rules
Unequal apportionment plan. Members
cooperative for a tax year after the year in
for figuring the cooperative’s tax in the
of a controlled group may elect an
which the patronage occurred.
year nonqualified written notices of
unequal apportionment plan and divide
Patronage dividends include any
allocation are redeemed. The cooperative
the taxable income brackets as they want.
amount paid to a patron by a cooperative
is entitled to:
There is no need for consistency among
based on the quality or value of business
taxable income brackets. Any member
(a) A deduction in the tax year the
done with or for that patron under a
may be entitled to all, some, or none of
nonqualified written notices of allocation
pre-existing obligation of the cooperative
the taxable income bracket. However, the
are redeemed (if permitted under section
to pay that amount.
total amount for all members cannot be
1382(b)(2) or (4) or section 1382(c)(2)(B))
The amount is determined by
more than the total amount in each
or
reference to the net earnings of the
taxable income bracket.
(b) A tax credit based on a
organization from business done with or
Line 2b. Members of a controlled group
recomputation of tax for the year(s) the
for its patrons.
are treated as one group to figure the
nonqualified written notices of allocation
Patronage dividends may be in:
applicability of the additional 5% tax and
were issued. See instructions for line 32f.
Money,
the additional 3% tax. If an additional tax
Qualified written notices of allocation,
Amounts paid to patrons are not
applies, each member will pay that tax
or
patronage dividends if paid:
based on the part of the amount used in
-15-

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