Problem: Company X is a calendar year, accrual method corporation. Company X has an incentive award bonus plan for all employees. Company X currently accrues for both books and tax bonus amounts earned based on performance criteria met during the year that is expected to be paid within 2 ½ months after year end. During 2025, the new tax senior analyzes the bonus plan provisions and determines that bonus amounts are not fixed and determinable until paid because of certain provisions in the plan that allow the exercise of negative discretion after year end. Company X desires to mitigate the exposure and remediate any possible adverse financial statement reporting consequences. (Assume this change will not qualify for automatic provisions).
a. What are Company X's options regarding the method of accounting?
b. Can Company X file an application to change the method of accounting? When do they need to file by?
c. Company X is in the process of preparing their 2024 tax return. Can the company change their method for 2024? How should the company file their 2024 tax return? What about the 2025 tax return?
d. What is the Section 481(a) adjustment? e. How will the company know their method?