Do not bury your P-Card tax skeletons.

Trying to hide from auditors or cover up a poor tax strategy? Lack of an effective process puts your organization at risk of a use tax assessment that could reach or exceed $1M. Because P-Cards are associated with a different purchase-to-pay process than other payment methods, they also require a different approach to managing U.S. sales tax compliance. While tax is not a topic many people embrace, you can satisfactorily address it. To help you improve, I consulted with tax veteran Greg Anderson, Application Design Resource, LLP (ADR), to compile the following plus additional tax content.

Compliance Begins with Teamwork

Greg observed that, most of the time, the P-Card program management team and the internal tax group never communicate. Like cats and dogs, they do not typically understand each other’s worlds or establish a relationship. For instance, the tax folks do not know what type of P-Card data is available, which is unique compared to other payment methods, so they do not know what to request when trying to resolve an issue. If you manage a P-Card program, do not assume that the tax group is handling your tax compliance. Schedule a meeting with them today.

Are you prepared for a tax auditor to dig into your P-Card program?

Are you prepared for a tax auditor to dig into your P-Card program?

The Auditor is the Alpha Dog

Understand that the auditor’s job is to make sure your organization accrues the correct amount of use tax on taxable purchases for which the supplier has not collected sales tax. A tax assessment to your organization will occur if the auditor cannot find documentation of either the payment of sales tax or the accrual of use tax; for example, if receipts or images are not available/missing or no longer legible because of mishandling or fading.

Implement an Effective Process

If your organization does not have an established tax compliance process for the P-Card program, you could find yourself scooping up the remains. The auditor’s only option is to work with a larger sample and request hundreds of receipts for the full statutory period. This can be frustrating and time consuming for both the auditor and your organization. Larger samples may also include more errors, which increase the amount of the assessment. 

Learn from the Tax Audit Results

While very few people enjoy a tax audit, it is no reason to bury your head in the ground. Through the results, the auditors are giving you a bone that can be a valuable contribution toward making your program more tax efficient. If your organization receives an assessment, ensure you make accruals on those purchases going forward. If the auditor found over payments—your organization was accruing use tax on transactions where the supplier was already collecting sales tax—end that practice going forward.

Additional Tax Content


About the Author

Blog post author Lynn Larson, CPCP, is the founder of Recharged Education. With more than 15 years of Commercial Card experience, her mission is to make industry education readily accessible to all. Learn more

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I hereby renew my vows to card acceptance.

The term irreconcilable differences is often associated with divorce, but it also applies to the ongoing battles over card acceptance fees. I find the related litigation tiresome, so I am offering a different perspective below. However, I also share some litigation/regulation highlights elsewhere on my website, including something new from Colorado.

My Card Acceptance Experience

With Valentine’s Day looming in the United States, it seemed appropriate to use this blog post to declare my love of card payments from a supplier’s point of view. I do not receive the lowest fee out there, but, considering various factors, I would not expect royal treatment. I simply expect a fair deal. Rather than focusing on the fee alone, I view my entire value package—namely, electronic payments that I do not need to touch and a no-surprise, consistent fee. I am grateful, not disgruntled like many suppliers.

Relationships Can Go Wrong

I realize other card acceptance relationships might be rocky, even if they started blissfully. The romance can fade. There are suppliers who outgrow their acquiring partners and the initial deals. Others are wooed by rates that dazzle and cause an immediate attraction. Such rates could be masking an ugly side—low fees that are unattainable most of the time due to corresponding requirements a transaction must meet. If something looks too good to be true, it is worth uncovering the faults before committing.

Suppliers who have already committed to a tedious and/or unfair fee structure should weigh their options. Renegotiating a better deal might be possible. If the partnership cannot be saved (here enters irreconcilable differences again), the supplier should seek a business divorce and move on.

I have a business owner friend who did just that. He initially pursued card acceptance with his bank; it was a natural choice given the banking relationship. However, it quickly proved to be the wrong choice. A couple $1,000 transactions from two different customers ended up incurring fees amounting to nearly 7%! The same thing could have happened with a non-bank partner. The devil is in the details. Fortunately, this story has a good ending. He later switched to a different card acceptance route that works better for him.

For suppliers, the key to loving card acceptance lies in finding the right acquiring partner and appreciating the entire value package. 

For suppliers, the key to loving card acceptance lies in finding the right acquiring partner and appreciating the entire value package. 

Advice to Suppliers

In the business-to-business (B2B) payments world, it is critical to find an acquirer who specializes in this space; Commercial Cards are unique and have more complexities. I invite industry providers and others to expand on this advice in the comments section below, but no bashing of another provider, please!

A supplier always has the option of forgoing card acceptance altogether, but other payment methods have costs, too, and other drawbacks. Suppliers tend to forget this. I encourage any supplier who is dissatisfied with card acceptance to channel their energy into:

  • evaluating the entire card acceptance value package for their business
  • understanding and calculating the costs of other payment methods
  • finding a different acquiring partner, if necessary

Let’s show a little love for the positive things payment cards have allowed businesses and consumers alike to do. If we really need to become riled up over something, look no further than the industry with unpredictable, ever-changing pricing; excessive fees; an unpleasant environment for customers; and inconsistent service. Need I say more? Airlines. They give everyone plenty of reasons to be disgruntled.


About the Author

Blog post author Lynn Larson, CPCP, is the founder of Recharged Education. With more than 15 years of Commercial Card experience, her mission is to make industry education readily accessible to all. Learn more

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Procurement fraud and card misuse reenter the news.

Two different situations, but both yielded negative press. The following stories once again highlight control gaps that allowed fraud and misuse to occur. While we cannot control the media, we can learn from the mistakes of others. To keep your organization out of the “bad news” arena, take necessary actions now to improve internal controls. 

If your card program (or your client's card program) has been the subject of a good media report, I encourage you to share it within the comments section below. 

Avoid being the topic of bad news by utilizing effective internal controls.

Avoid being the topic of bad news by utilizing effective internal controls.

1. Procurement Fraud 

The Financial Industry Regulatory Authority (FINRA) permanently barred a former Charles Schwab financial representative after he purchased and resold approximately $1 million of office equipment.

FINRA records note that, between February and August 2014, the rep used the firm’s corporate procurement system to purchase office equipment for his branch office in Florida, which he later sold to various people to obtain cash for himself. Multiple organizations reported this story last November, including ThinkAdvisor.

Control Gaps

I doubt that it was typical for a rep with his size of office to spend nearly $1M on office equipment in less than a year using corporate funds. Such activity could not even be explained away as a new rep establishing an office (it would be quite an office!), as he was a 15-year veteran. I assume that the control gaps included:

  • Overly trusting management who did not consider or believe that a veteran employee would commit fraud 
  • No budget for the rep to adhere to 
  • No purchase limit/threshold preventing the rep from spending above “X” amount via the procurement system each month 
  • No one monitored his purchases or visited the branch office for purchase follow up 
  • Lack of fixed assets tracking 
  • No one reviewed spend reports to compare the rep’s monthly spend total to previous year(s) or to other similar sized reps in an effort to identify out-of-norm spending activity

2. Card Misuse/Abuse

Right in my own backyard, the local newspaper, Star Tribune, reported last month on card misuse and abuse within the Minneapolis Public Schools (MPS). The issues included inappropriate purchases, lack of receipts (even though receipts are required) and out-of-policy purchases; for example, using the card at local restaurants when the policy only allowed meal purchases while on business travel. Top executives have been part of the problem. 

Fixing What is Broken

After reading the initial article on January 11, I contacted the author to offer my insight on the district's woes. A follow up article published by the Star Tribune on January 12 included some of my comments. (I garnered a modest 80 words.) My recommendations included the standard control best practices:

  • Assigning and enforcing accountability for the oversight role to ensure policies are followed by everyone, including executives 
  • Clear P-Card policies and procedures (P&P) 
  • Mandated training prior to card issuance and annually to stress key P&P, such as what is and is not allowed 
  • No tolerance for policy violations, including missing receipts 
  • More strategic MCC blocks; for the district, this could mean blocking restaurants and similar unless the cardholder will be traveling 
  • Obtaining reports from key suppliers that show off-contract purchases; for example, with the office suppliers vendor, are cardholders purchasing higher quality goods than what are allowed? 
  • Effective auditing on an ongoing basis to catch and remedy issues if/when they emerge


About the Author

Blog post author Lynn Larson, CPCP, is the founder of Recharged Education. With more than 15 years of Commercial Card experience, her mission is to make industry education readily accessible to all. Learn more

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