Developing Tribal Travel Policies
Using IRS and OMB Guidelines

In recent years, the Internal Revenue Service (IRS) informed numerous tribal employees that they owe substantial back taxes due to non-compliance with IRS regulations regarding employer-paid and reimbursed travel costs. Many tribes believe that if they only pay their employees per diem costs, no problems will result. Don’t be misled.

Organizations that pay travel costs should have “accountable” plans in place, but many do not. The issue of tribal or corporate credit cards creates another set of challenges. Attend this session and learn how to establish travel reimbursement plans that meet the accountability test and what to do if your plan doesn’t.

Learn what OMB’s “Super Circular” has to say about travel costs, including family-friendly travel allowances, as well as how the Tax Cuts and Jobs Act of 2017 impacts the deductibility of certain costs.

This class is a must for anyone dealing with tribal travel!

T O P I C S   I N C L U D E
Types of Travel Reimbursement
  • Actual — no limit
  • High-low
  • Accountable
  • Non-accountable
IRS Guidelines
  • How it defines “travel expenses”
  • When travel reimbursements become income
  • How reimbursements are reported to the IRS
  • Criminal sanctions
Non-Accountable Plans
  • Reporting as wages
  • FICA/FUTA withholding
  • Cost to employer
  • Avoiding non-accountable states
Accountable Plans
  • In-service rule
  • Documentation requirements
  • Per diem limits
  • Per diem over federal rates
Travel Advances
  • Risk
  • Accounting requirements
  • Vouchering out
  • Requirements for returning
  • Documentation
Credit Cards
  • Relationship to plan type
  • Documentation
  • Double-dipping
  • Receipt requirements
  • Danger signs
OMB's "Super Circular"
  • What do you need to be in compliance?
  • Where in the circular is travel addressed?
  • What travel-related changes have there been?
  • New family-friendly travel allowances
  • Importance of your tribe's written travel reimbursement policies
Entertainment Expenses
  • Legitimate business rule
  • Documentation requirements
  • While on travel
  • While at home
  • Avoiding personal income
  • George M. Cohen rule
  • In lieu of air travel
  • Two or more travelers
  • Current mileage rates
  • Tolls
  • Miscellaneous costs
Per Diem
  • What MIE is
  • Maximum allowable — OMB Cost Principles
  • What happens to savings?
  • When per diem is taxable
Special Situations
  • Compliance with OMB Cost Principles
  • Excess baggage charges
  • First-class air travel
  • Cabs
  • When tips are allowed
  • Comped hotel rooms
  • Employer-provided vehicles:
    • How taxed
    • How reported
    • When excluded

    *Topics subject to change.

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