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ThomasS2 (New Mexico)
Posts: 5
Posted:
If an HOA files an IRS Tax Form 1120-H, and does not qualify under the 90% expenditure test, what are the tax consequences for the HOA? Assuming the IRS calls the HOA on this point. Also, are there better guidlines as to what qualifies for the 90% test than those contained in the Instructions for Form 1120-H?
RogerB (Colorado)
Posts: 5,067
Posted:
Thomas, perhaps you are not interpreting the 90% rule correctly. I have never seen an HOA which did not quality under the 90% rule when reserve funds are properly included as expenses.
RogerB (Colorado)
Posts: 5,067
Posted:
Following is further clarification on my response:

Only that portion of reserve funds which are spent are included for calculation in the 90% rule.

The rule requires and I quote "90% of the association’s expenditures for the tax year must consist of expenses to acquire, build, manage, maintain, and care for property which includes current and capital expenditure." For example if there is income of $100,000, expenditures from the operating and reserve accounts of $70,000 and $66,000 of that $70,000 qualifies as expenditures for the property this qualifies at 94+%. The other $30,000 may go into a reserve fund but it does not qualify as an expenditure. It is not an expenditure; nor is it taxable income IMO.

Following is the rule as posted by the IRS in the 1120-H instructions:

"Item C. 90% expenditure test.
At least 90% of the association’s expenditures for the tax year must consist of expenses to acquire, build, manage, maintain, and care for property, and in the case of a timeshare association, for activities provided to, or on behalf of, members of the timeshare association. Include current and capital xpenditures. Use the association’s accounting method to figure the total.
Include:
1. Salary for an association manager or secretary.
2. Expenses for gardening, paving, street signs, security guards, and property taxes assessed on association property.
3. Current operating and capital expenditures for tennis courts, swimming pools, recreation halls, etc.
4. Replacement costs for common buildings, heating, air conditioning, elevators, etc.
Do not include expenditures for property that is not association property. Also, do not include investments or transfers of funds held to meet future costs. An example would be transfers to a sinking fund to replace a roof, even if the roof is association property."

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