The JMML Foundation Policy on Donated Goods and Services 23/08/06 Filing # JMMLF Policy on Recording Donated Goods and Services I. Purpose: This policy describes how JMMLF will record the receipt of donated goods and services per IRS and GAAP requirements. II. References 1. SFAS Information: http://www.fasb.org/pdf/fas116.pdf 2. IRS Home Page: http://www.irs.gov – search for Form 990 for the appropriate tax year III. Definitions 1. GAAP: Generally Accepted Accounting Procedures 2. SFAS: Statements of Financial Accounting Standards IV. Policy 1. GAAP Information: There is a difference in the requirement of reporting for donated services between Generally Accepted Accounting Procedures (GAAP) and Federal Tax Filing (form 990). GAAP requires a charity to record the fair market value of donated goods/facilities/services on the books. Recording such items is a requirement for a successful audit. SFAS 116 requires the fair value of donated services to be recognized in the financial statements IF the services EITHER (a) create or enhance a financial asset (b) require specialized skills, are provided by persons possessing those skills, and would need to be purchased if not donated. Here is a specific example from literature BOARD MEMBER SERVICES. “While board members often possess specialized skills their services should be recorded ONLY if they are used in connection with a building or renovation project or if they would be purchased if not donated. To illustrate, the services of a CPA who is the board’s treasurer who reads financial statements and reports the financials to the board would NOT meet the criteria for recognition. However if the CPA prepares the form 990, that WOULD be recognized because if the board member didn’t do it, the charity would have to pay an outside CPA to do it. Under SFAS 116 Donated Materials (also called donated goods in this document) is recorded in “contributions” and in either inventory or expense at the fair market value. As a side note “unconditional promises to give donated materials” are also recorded. It is noted that it is sometimes difficult to determine “fair value” of items. The guidance suggests some methods which include: catalogs, vendors, independent appraisers, and estimated sales price. (We can also use technologies such as ebay to find the value of 1/6 The JMML Foundation Policy on Donated Goods and Services 23/08/06 Filing # similar items.) In regards to “donated materials for fund raising purposes” the end result is that contributions are netted to the amount received for the item and cash is debited for the amount received for the item. 2. IRS Form 990 Information: Federal Tax Filing in the form of form 990 does NOT require the reporting or inclusion of any value of donated services/goods/facilities. But it does ALLOW the reporting of the information in a few different sections of the report. In parts IV-A “Reconciliation of Revenue per Audited Financial Statements with Revenue Per Return,” and IV-B “Reconciliation of Expense per Audited Financial Statements with Revenue Per Return” of the 990 report there is a reconciliation of the GAAP books to the Federal Books where the GAAP books include donated goods and services and the Federal Books do NOT include donated goods and services. The IRS line instructions for those lines are as follows: Note that this section is only required if the charity has had an audit Lines b2 in part IV-A and IV-B is the reconciling line item for donated goods and services. Separately there is another opportunity to present the value of donated goods and services in part VI “Other Information” line 82b. In that line you also enter the value of donated goods and services. The intent of having line 82b on the form is for INFORMATIONAL purposes only. That number is not included in total revenue or expense calculations from a federal tax standpoint. The IRS line instructions for line 82b are as follows: 2/6 The JMML Foundation Policy on Donated Goods and Services 23/08/06 Filing # Note the point that filling this in is optional and is used by charities to help make public their donated goods and services. This number is for reference only, it is not included in the other areas of number reporting that the IRS cares about (Parts I, II) 3. JMMLF Policy JMMLF will record the value of donated goods and services such that they are included in GAAP financials to facilitate any future audit. Those items will be tracked separately so they are easily identified and taken out for federal filing. A work paper should be maintained that reconciles the balance of each of the donated goods and the donated services accounts, the content of that work paper is populated from provided goods donation and service donation templates. The amount of donated services will be included in the optional parts of the federal filing so that donors who view our 990 on-line can have visibility to the amount of our donated goods and services. For donated services the guideline is that the service must be provided by a professional and it must be something that JMMLF would need to purchase if not otherwise provided. Currently we identify 3 specific items that fall into this: 1) The services provided by our board member to fill out and file tax filing, 2) the services provided by our web programmer to create and maintain the website, and 3) the service provided by our board member to host the website. Other services could be identified in the future as long as they meet the standard of “be provided by a professional and it must be something that JMML would need to purchase if not otherwise provided.” The finance committee of the board would apply that rule to any new service not listed herein. We need to record donated goods as well, specifically as it relates to the silent auction and items associated with the proposed golf outing. 4. Examples of recorded donations 3/6 The JMML Foundation Policy on Donated Goods and Services 23/08/06 Filing # We require the below service and goods templates to be filled in to support any service or good amounts we record. Examples of accounting are noted below as well as templates. Example: Accounting for Service Donation of $500 worth to tax filing work Donated Accounting Fees Donated Services Contributions Debit $500 Credit $500 [expense account] [revenue account] Example: Accounting for Service Donation of $1000 worth of web programming Donated Expenses – Internet Donated Services Contributions Debit $1000 Credit [expense account] $1000 [revenue account] Example: Accounting for Donation of internet server space/hosting service $300 Donated Expenses – Internet Donated Services Contributions Debit $300 Credit $300 [expense account] [revenue account] Example: Donated Good auctioned off for $100, where good was never held in inventory such as items auctioned in silent auction or items donated for golf outing. There are 2 steps to the first recording the donation, second recording the receipt of cash. Debit Step 1 record the donation Donated Goods Expense Donated Goods Contributions $100 Step 2 record the cash Cash received Special Events Income $100 Credit $100 [expense account] [revenue account] $100 [expense account] [revenue account] Note step 1 records the value of the donation at fair market value. In the example above the realized value (cash received) is equal to the fair market value. But if in reality there is a difference, then an adjusting entry needs to be entered to the entries in step 1 to adjust the value of the donation to the realized value. Section 1303.7 of our audit materials specifically notes “Donated Materials Used for Fund Raising Purposes. Organizations may receive contributions of gifts in kind (such as tickets, gift certificates or merchandise) to be used for fund raising purposes. …. When an organization receives an item for fund raising, it should be measured at fair value. 4/6 The JMML Foundation Policy on Donated Goods and Services 23/08/06 Filing # The difference between the fair value and the amount received for the item (realized value) should be recorded as an adjustment to the original contribution amount.” For example we receive a donation with back up indicating that the fair market value is $100, later we auction it off for $80. Then we have 3 steps to record this entry. A. record the donation at fair market value B. recognize the $80 realized value. C. adjust the donated value to the realized value. Debit Credit Step 1 record the donation at fair market value Donated Goods Expense $100 Donated Goods Contributions $100 [expense account] [revenue account] Step 2 record the cash Cash received Special Events Income [balance sheet account] [revenue account] $80 $80 Step 3 adjust the donation to the realized value (debit the contribution account by $20 which is the difference between FMV and realized value) Note if the realized value is greater than the FMV then the contribution account is credited. Debit Donated Goods Expense Donated Goods Contributions $20 Credit $20 [expense account] [revenue account] In reality for JMML, the likelihood is that for the accounting the donation and the silent auction value will happen simultaneously. If that is the case, we can limit our accounting down to just 2 steps, but the values used in the 2 steps are not the fair market value, they are the actual realized cash value. In our example the actual realized value is $80. Debit Step 1 record the donation Donated Goods Expense Donated Goods Contributions $80 Step 2 record the cash Cash received Special Events Income $80 Credit $80 [expense account] [revenue account] $80 [balance sheet account] [revenue account] 5. Templates (with Examples) for Recording Donated Goods and Services 5/6 The JMML Foundation Policy on Donated Goods and Services Service Template Person Providing the Service Description of Service Specialized Skills Method Used to Determine Fair Market Value (rates, dates, hours, rationale, etc.) Fair Market Value of the Service Justification statement – would JMML need to have purchased this if it was not donated? Goods Template Person Providing the Good Description of the Good Date of Donation Method Used to Determine Fair Market Value Fair Market Value of the Good Actual Cash Amount Received by JMML for the Good 23/08/06 Filing # Joe Smith Accounting service to file IRS form 990 CPA Received quote of hourly rate from another CPA of $100 an hour, Joe worked 10 hours during week of 6/1/2006-6/7/2006 $1000 Yes, JMML would have needed to purchase this because JMML is required by law to make this filing. Joe Smith New Sony DVD Player X23 8/5/2006 Internet search of average retail cost, print out from Best Buy website attached $100 $80 V. Personnel Responsibilities 1. JMMLF Treasurer – records the receipt of donated goods and services per the 2. JMMLF Finance and Audit Committees – review the records to ensure complete entries and proper accountability VI. Periodic Reviews 1. Reviewer: Finance Committee 2. Method: Will ensure all records are complete and correct prior to submitting annual IRS and GAAP forms 3. Periodicity: Annually. VII. Date of Effect: Immediately Signature of Chair/Acting Chair _//Signed by Ina Masten, chair// _______________ 6/6