An employer reimburses travel expenses only when employees submit receipts within 60 days, and requires any advance excess to be returned within 120 days. How are the reimbursements treated?
An accountable plan requires a business connection, adequate substantiation within a reasonable time (safe harbor: 60 days) and return of excess amounts within a reasonable time (safe harbor: 120 days). Reimbursements under such a plan are not wages. Payments under a nonaccountable plan are wages subject to withholding. Source: Treas. Reg. 1.62-2(c)-(g); Pub. 463 (2025), chapter 6. Tax year: 2025 (law as of 31 Dec 2025).
Treating all expense reimbursements as wages.
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