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          Table 5. Example 1 book-tax reconciliation assuming the options are NQOs

                                 Year 1      Year 2     Year 3    Year 4

          Book income            $  800,000    $  800,000    $  800,000  $ 1,000,000
          +/- Book-tax differences  +$  200,000  +$  200,000 +$  200,000  -$  240,000 (net of: -$600,000 temp + $360,000 perm)
          Taxable income         $ 1,000,000    $ 1,000,000    $ 1,000,000  $  760,000



         $240,000 ($4 per share bargain element   finally knows in year 4 is an incremental   origination and reversal of the temporary
         × 60,000 shares purchased). Table 4   $360,000 of financial expense (in total).   component of the book-tax difference.
         on p. 43 presents the book and tax ex-  In this example, the permanent element   Tables 6A and 6B on p. 45 show O’s
         pense figures.                    is unfavorable because O Inc. will never   income tax footnote current/deferred
           Because both financial and tax ac-  get a tax deduction for that portion of   income tax breakout and rate rec for Ex-
         counting will recognize an expense for   its total book expense. In other words,   ample 1 under the NQO assumption in
         the NQOs, O Inc. originates the book-  over time it got less tax expense than   years 1–4. Because the book-tax differ-
         tax difference as a temporary one. As   book expense. Therefore, it will add   ence in the vesting years is temporary, its
         such, the book-tax difference in years   the $360,000 permanent difference in   effect is detailed in the current/deferred
         1–3 increases the related DTA each   the book-tax reconciliation. The final   expense breakout, but it does not shift
         year, as shown in the final two columns   column of Table 5 shows the two-  ETR and does not appear on the rate
         of Table 4. The annual DTA increase   pronged effect in year 4. Again, note that  rec. Similarly, the $600,000 portion of
         for each vesting year equals $42,000   combining these two effects results in a   year 4’s book-tax difference that reflects
         ($200,000 annual book-tax temporary   net $240,000 subtraction (-$600,000 +   the complete reversal of the $126,000
         difference × 21% tax rate at reversal).   $360,000), which ties to the difference   DTA also does not trigger a reconciling
           In year 4, O Inc.’s book-tax difference   between year 4 book compensation ex-  item on the rate rec but does affect the
         equals $240,000, reflecting $0 book   pense ($0) and year 4 tax compensation   current/deferred breakout that year.
         expense after vesting and tax expense   expense ($240,000) for the NQOs.  In contrast, the $360,000 permanent
         based on the $4 per share bargain   Under the NQO assumption, O     component of year 4’s $240,000 book-
         element. However, for its Topic   Inc. will record the Topic 740 journal   tax difference does affect ETR and re-
         740 analysis, O Inc. must break this   entries shown below each year. As   quires O Inc. to make an adjustment on
         difference into both a temporary and   before, current tax expense is calculated   its rate rec. Only by separating the book-
         a permanent component. First, the   by multiplying taxable income by the   tax difference in year 4 into the tempo-
         $240,000 year 4 difference must reflect   current 21% tax rate. The deferred entry   rary and permanent components can one
         O Inc. fully reversing the DTA to an   corresponds to the tax effect of the   clearly see the effect of the permanent
         ending balance of zero because the
         book-tax difference is fully resolved
         that year (i.e., neither set of books will   Journal entries accompanying Table 5
         have any more expense related to the
                                            In years 1, 2, and 3:
         exercised options in future years). So,
                                            Current income tax expense       $  210,000
         a portion of the $240,000 book-tax
                                            Deferred tax asset               $  42,000
         difference includes the effect of the
         $600,000 cumulative temporary          Income taxes payable                    $  210,000
         difference reversing. The reversal yields   Deferred income tax expense        $  42,000
         a $600,000 subtraction in the year 4
         book-tax reconciliation (offsetting the   In year 4:
         $200,000 addition in each of the first   Current income tax expense  $  159,600
         three years), as shown in Table 5, above.  Deferred income tax expense  $  126,000
           The $240,000 year 4 book-tax dif-    Income taxes payable                    $  159,600
         ference also includes the effect of the   Deferred tax asset                   $  126,000
         permanent component, which O Inc.



         44  August 2022                                                                      The Tax Adviser
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