Turo General guidance on the taxation of business income
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Turo | General guidance on the taxation of business income January 2023 Disclaimer This documentation was prepared by Ernst & Young LLP (“EY”) at the request of Turo. This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. This documentation contains information in a summary format. It does not provide tax advice to any taxpayer because it does not take into account any specific taxpayer’s facts and circumstances. It assumes that the only business use of a vehicle is Turo-related, that no other business uses for such vehicles exist, and that all business use occurs within the United States of America. Hosts who choose to use the Standard Mileage Rate method for computing vehicle expenses recognize that the protection component of Turo fees represents an estimate and that such amounts may be adjusted upward or downward upon subsequent IRS examination. Readers are encouraged to consult with professional advisors for advice concerning specific matters before making any decision or taking a position on any tax return, and EY and Turo disclaim any responsibility for positions taken by taxpayers in their individual cases or for any misunderstanding on the part of readers. While EY has used its best efforts in preparing this documentation, it makes no representations or warranties with respect to the accuracy or completeness of the contents of this documentation and specifically disclaims any implied warranties. Neither Turo nor EY shall be liable for any loss of profit or any other damages, including, but not limited to, direct, indirect, special, incidental, consequential, or other damages in connection with the information contained in this documentation. Please refer to the Car Sharing Regulations guide at https://help.turo.com/en_us/car-sharing- regulations-SJTQH4lV5 for additional general information about hosting in the United States. 2
Turo | General guidance on the taxation of business income January 2023 Key takeaways: Operating your business on Turo As a Host operating your business on Turo in the U.S., you are responsible for reporting your business earnings each year on your income tax return and paying any applicable income and/or self-employment taxes. The sections that follow in this tax guide will provide more detail on how to report your business income, potential tax deductions you can take, what your tax reporting obligations are, and resources that are available to you as a Turo Host. This guide is an overview of the federal income tax rules; it does not address state income tax rules that may differ from the federal rules. To make it easier to navigate this guide and how to file your taxes, we’ve included an overview of the key takeaways: A. How to report your gross income when you receive a Form 1099-K (or even if you don’t) B. How to report tax deductions for items attributable to gross income from your Turo Form 1099-K C. Other tax deductions you may be able to take for your business and how to report them — specifically, the choice between using the Standard Mileage Rate or Actual Expenses method for deducting automobile expenses A. How to report your gross income when you receive a Form 1099-K (or even if you don’t) If you qualify, you will receive a Form 1099-K from Turo by January 31. You will report the gross income on Schedule 1, Page 1, line 8(l) or Schedule C, line 1 in your income tax return. See Exhibit A for an example of Schedule 1, Page 1 and Exhibit C for an example of Schedule C. You may not receive a Form 1099-K from Turo. Even if Turo does not send you a Form 1099-K, you will still need to report your income for income and/or self-employment tax purposes. You should continue to follow the rules of this guide, utilizing your earnings and tax summary as your pro forma Form 1099-K. B. How to report tax deductions for items included in your Turo Form 1099-K gross income The most important items in your earnings and tax summary to look out for when receiving your Form 1099-K from Turo include cancellations and Turo fees. Once you determine these amounts, you will be able to deduct them as business expenses in the same year. See section 2 (“Rental income”) and section 4 (“Vehicle expenses that can be deducted”) for more information. C. Other tax deductions you may be able to take for your business and how to report them Besides cancellations and Turo fees, you can deduct other expenses, as long as they qualify as business expenses. This includes unreimbursed out-of-pocket expenses and reasonable costs of managing your business. In addition, you must decide whether to use the Standard Mileage Rate method or Actual Expenses method when deducting vehicle-related expenses. In general, you should choose the method that generates the largest deduction for you, but you should be aware of certain limitations that exist depending on which method you choose. Report qualifying deductible expenses on Schedule 1, Page 2, line 24(b) or Schedule C, lines 8–27a, as appropriate. 3 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 See section 4 (“Vehicle expenses that can be deducted”) and section 8 (“How to report rental income and expenses”) for more information. See section 5 (“Flowchart for reporting vehicle-related expenses”) for a high-level overview of the Standard Mileage Rate method vs. Actual Expenses method to deducting automobile expenses. See Exhibit B for an example of Schedule 1, Page 2 and Exhibit C for an example of Schedule C. 4 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 Table of contents 1. Who is subject to U.S. income tax? .................................................................................................. 6 2. Rental income .................................................................................................................................. 6 3. What tax information will Turo provide? ............................................................................................ 7 4. Vehicle expenses that can be deducted ........................................................................................... 8 5. Flowchart for reporting vehicle-related expenses .............................................................................. 9 6. Limit on rental losses ..................................................................................................................... 16 7. Self-employment income and qualified business income (“QBI”)..................................................... 17 8. How to report rental income and expenses..................................................................................... 17 9. Reporting payments to independent contractors............................................................................. 18 10. How is (net) rental income taxed? (federal) .................................................................................... 18 11. Quarterly estimated tax payments .................................................................................................. 18 12. Sale of vehicle used as rental property ........................................................................................... 18 13. Documents to be retained .............................................................................................................. 18 14. Other resources ............................................................................................................................. 19 15. Exhibit A – Schedule 1, Page 1 (Form 1040) .................................................................................. 21 16. Exhibit B – Schedule 1, Page 2 (Form 1040) .................................................................................. 22 17. Exhibit C – Schedule C (Form 1040) .............................................................................................. 23 18. Exhibit D – 2022 Tax Rates for Individual Taxpayers ...................................................................... 24 5 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 1. Who is subject to U.S. income tax? I am a Turo Host. Am I subject to income tax in the U.S.? You are subject to U.S. income tax if you have U.S. sourced income. Generally, income derived from U.S. assets, such as vehicles located in the U.S., is U.S. sourced income and subject to U.S. income tax. Domestic rental income (i.e., rental income from a vehicle located inside the U.S.) is taxable in the U.S. regardless of where the person in receipt of that income resides. For example, an individual living outside the U.S. who is in receipt of rental income from a U.S. vehicle is still subject to tax in the United States. Types of taxpayers: cash basis vs. accrual basis If you are subject to U.S. income tax, you must report your rental income as a cash-basis or an accrual- basis taxpayer. Most individuals are cash-basis taxpayers. If you are a cash-basis taxpayer, you report rental income on your return for the year you actually or constructively receive it and you deduct all expenses in the year you actually pay them. You are a cash- basis taxpayer if you report income in the year you receive it, regardless of when it is earned. Most individuals are cash-basis taxpayers. You constructively receive income when it is made available to you, for example, by being credited to your bank account. If you are an accrual-basis taxpayer, you generally report income when you earn it instead of when you receive it and you deduct expenses when you incur them instead of when you pay them. Accrual-basis taxpayers should engage a tax advisor to ensure that rental income and expenses are correctly reported. 2. Rental income[1] If you are subject to U.S. income tax, you must include in your gross income all amounts you receive as rent. Rent is the gross amount of payment received (before any expenses are deducted) for the use of your vehicle. It can also include payments received for any goods or services that are provided, e.g., optional trip add-ons like prepaid fuel and extras. Taxable rental income is the gross amount of rent received less any allowable expenses. This can also be referred to as net rental income. If the allowable expenses are greater than the gross amount of rent received, a rental loss will arise. Taxable rental income/(loss) must be reported and calculated on Form Schedule 1 (Form 1040) or Form Schedule C (Form 1040). See section 8 (“How to report rental income and expenses”). [1] - Peer-to-peer car sharing income is not specifically identified as a category of income in the current Internal Revenue Code. The IRS considers payments received for the use or occupation of property as rental income. 6 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 In addition to amounts you receive from Turo as normal vehicle rental payments, you may also receive other amounts that should be carefully considered in determining the amount of gross rental income to report. Examples of such amounts that may be includible in gross income: Cancellations – Any amounts returned to a driver due to a cancellation are not included as net rental income. Cancellations will be listed in your earnings and tax summary and should be included as income and also taken as a deduction. Turo fees are included in rental income. These fees represent Turo’s share of the fees from renting your vehicle. At the end of the year, Turo will provide an earnings and tax summary detailing how much of the gross rental income consisted of Turo fees. Depending on the method you choose to deduct automobile expenses, either 100% or 70% of such Turo fees are deductible. See section 5.III (“Turo fees”). Host Incentives that are paid by Turo to you are included in your gross income. Reimbursements – If Turo reimbursed you for any expenses that were incurred because of your driver, those payments would neither be gross income nor deductible expenses. The most common example of this would be parking and/or tolls that were charged to you when your driver used your vehicle. 3. What tax information will Turo provide? Turo will provide to you a Form 1099-K (if eligible) and an earnings and tax summary. Both of these documents should be made available to you no later than January 31. Additional details can be found on your Host dashboard. Form 1099-K requires reporting of unadjusted gross sales, which as described earlier is defined as transactions without adjustments for credits, service fees, reimbursements, or any other amounts. In other words, your gross sales (defined by Turo as “gross earnings”) are the total amounts received for each Turo booking, before being reduced by cancellations or Turo fees, plus any other payments received from Turo (e.g., Host Incentives). On the other hand, your trip earnings, reflected in the earnings section of your Turo host hub, show your trip earnings but do not include Turo fees, Host Incentives, or host cancellation fees. To reconcile your trip earnings to your gross earnings, simply subtract the Turo fees, host incentives, and host cancelation fees from your gross earnings reported on your Tax summary of Form 1099-K. Please refer to Exhibits A–C, which include a snapshot of your earnings and tax summary, which will help you populate either your Schedule 1, Page 1 and 2 or Schedule C. 7 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 4. Vehicle expenses that can be deducted As outlined above, taxable rental income is the gross amount of rent received less any allowable expenses. In general, a deductible or allowable expense is one that is ordinary and necessary, has actually been paid (for a cash basis taxpayer), and is not regarded as capital in nature. Examples of deductible expenses include: Cleaning and maintenance services, including car washes and cleaning supplies purchased Gasoline and oil changes Interest on a loan taken out to buy the vehicle Turo’s Protection Plan, subject to certain restrictions Lease payments Fees paid to collect rental income, e.g., service fees charged by Turo Repairs that are not covered by insurance Tires Depreciation on amounts paid to acquire the vehicle, subject to certain limitations (see section 5.V “Depreciation,”) The cost of managing the property, e.g., vehicle registration fees, legal fees, and accountancy fees incurred by a Host in connection with renting the vehicle Miscellaneous items such as chairs, child car seats, beach umbrellas, water bottles, and breath mints that are provided to drivers for a fee or as a convenience This list is not exhaustive. 8 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 5. Flowchart for reporting vehicle-related expenses There are two options you may use to deduct your vehicle-related expenses. The following flowchart will help you determine the better method to use. In general, you should pick the method that results in lower net rental income. A more detailed discussion related to expenses will follow. (A) Choose one of the following two options Standard Mileage Rate method Actual Expense method Deduction based on business use miles Deduction based on your actual vehicle expenses multiplied The rate is 58.5 cents/mile for miles driven between 1/1/22 – by your vehicle’s business use percentage (“BUP”) 6/30/2022 and 62.5 cents/mile for miles driven between Note: This method may allow you to claim a Section 179 7/1/22 – 12/31/22. deduction or bonus depreciation deduction, depending on Note: Standard mileage includes depreciation, lease your BUP. payments, maintenance and repairs, gasoline, oil, insurance and/or registration payments. Note: This method is not permitted if you have claimed or want to claim a Section 179 deduction or bonus depreciation deduction. (B) Deduction instructions Multiply your business use miles by the standard mileage Divide your total mileage driven during the year between rate in each separate 6-month period to determine the business use and personal use. Determine your BUP by deductible amount of vehicle-related expenses. dividing the business use miles by the total miles driven. (C) Applying business use % to business expenses BUP is 50% or less BUP is more than 50% [1] Add allocable interest expenses, if Note: You are not eligible to claim Section Note: You may be eligible to claim applicable 179 depreciation or bonus depreciation. Section 179 depreciation or bonus [1] depreciation. Multiply your allocable vehicle expenses [1] by your BUP to determine your deductible Multiply your allocable vehicle expenses [2] Add your non-allocable business allocable vehicle expenses. by your BUP to determine your deductible expenses allocable vehicle expenses. [2] Add your non-allocable business expenses Add 70% Turo fees per your earnings and tax summary Add 100% Turo fees per your earnings and tax summary (D) Forms to file [3] [3] Non-material participant Material participant IRS Form: Schedule 1 – Additional Income and Adjustments to IRS Form: Schedule C – Profit or Loss from Business Income Instructions: Use Sch C, lines 8 – 27(a) to report your Instructions: Use Schedule 1, line 24(b) to report your deductible expenses computed above. Report your gross deductible expenses computed above. Use Schedule 1, line receipts from box 1(a) per the Turo-provided Form 1099-K on 8(l) to report your gross receipts from box 1(a) per the Turo- Schedule C, line 1. provided Form 1099-K. [1] Allocable expenses include costs that would apply to both business and personal use (e.g., depreciation, lease payments, maintenance and repairs, gasoline, oil, interest (but not insurance), and/or registration payments). [2] Non-allocable expenses include costs directly attributable to only business use (e.g. out-of-pocket expenses, equipment, etc.). Do NOT include any items for which Turo reimbursed you and reported as “Reimbursements” in your earnings and tax summary. [3] See section 8 for more detailed information on material vs. non-material participation. 9 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 I. Deduction methods: Standard Mileage Rate vs. Actual Expenses In the first year your vehicle was available for use in your business, you have the option of choosing which deduction methodology favors you more. Therefore, you may find it beneficial to perform calculations under both methodologies, choosing whichever one is more suitable for you. If you choose to use the Standard Mileage Rate method, it must be in the first year the car was available for use in your business. In later years, you are then permitted to switch between methods. If you use the Standard Mileage Rate method for a car you lease, that method must be used for the entire lease period (including renewals). If you used the Actual Expenses method in the first year the car was available for use in your business, then you must continue to use the Actual Expense method. NOTE: Turo does not track your business or personal miles driven. It is your responsibility to maintain adequate records to substantiate miles driven. Standard Mileage Rate method This method is the simplest way to deduct your expenses, due to the straightforward nature of reading your vehicle’s odometer to determine the business use miles. To calculate your expense deduction using the Standard Mileage Rate method, multiply the number of business miles driven during 1/1/22 – 6/30/22 by 58.5 cents/mile. Then multiply the number of business miles driven during 7/1/22 – 12/31/22 by 62.5 cents/mile. Add these two amounts to determine your deductible vehicle expenses for 2022. Other deductions not allowed: Since the Standard mileage rate represents a “standard” rate for all vehicle expenses, you are not permitted to deduct any additional allocable vehicle expenses related to depreciation, lease payments, maintenance and repairs, gasoline, oil, insurance, and/or registration payments. Note: Interest expense can be deducted under the Standard Mileage Rate method. Follow the instructions under the Actual Expense method, later, to determine the deductible portion of interest expense if you are otherwise using the Standard Mileage Rate method for tax reporting purposes. Certain Hosts are prohibited from using the Standard Mileage Rate method and must use the Actual Expenses method instead. The following prohibited Hosts include those who: Lease 5 or more vehicles at the same time Have already claimed a depreciation deduction for a vehicle under any method other than straight-line depreciation (see section 5.V “Depreciation”) Have already claimed a Section 179 deduction or special depreciation (AKA “bonus”) deduction on the vehicle (see section 5.V “Depreciation”) Claimed actual car expenses after 1997 for a car that was leased 10 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 Actual Expense method Under this method, in addition to tracking your vehicle’s business miles, you must also track your vehicle’s personal miles as well. You must also record of all the allocable expenses incurred in relation to your vehicle’s total use. This method requires more time and effort to compute, but may yield a larger deduction than the Standard Mileage Rate method. Under this method, your allocable expenses are all expenses that could be assigned to both business and personal use (e.g., depreciation, lease payments, maintenance and repairs, gas, oil (but not your personal insurance), and/or registration payments.) See section. 5.III “Turo fees” for details. For Hosts using the Actual Expense method, include interest expense in “allocable expenses” as listed in the previous paragraph. For Hosts using the Standard Mileage Rate method, calculate your allocable share of interest expense only (as outlined in the next paragraph) and include it as part of deductible expenses along with the Standard Mileage Rate deduction. To calculate the expense deduction using your actual expenses, you must first calculate your vehicle’s business use percentage (“BUP”) by allocating the total miles driven in the calendar between personal use and business use. Do so by reviewing and documenting your vehicle’s odometer throughout the year. Next, multiply the BUP by all the allocable expenses related to the vehicle. The result is your actual expense deduction. Limitations: Depending on your BUP, you may or may not be able to claim a Section 179 deduction or bonus depreciation deduction. If your BUP is 50% or less, you cannot claim Section 179 depreciation or bonus depreciation deduction; further, depreciation deductions may be computed under longer recovery periods and slower recovery methods. If your BUP is more than 50%, you are eligible to claim Section 179 depreciation or bonus depreciation (see section 5.V “Depreciation”). If your BUP shifts from more than 50% to 50% or less in any tax year, consult your tax advisor for additional details. Example: Standard Mileage Rate Your vehicle was placed in service for business use for the first time in 2022 and was driven for 5,500 miles for rental purposes. 2,000 of those miles were driven in the first six months of 2022 and the remainder of the miles were driven in the last six months of 2022. You can deduct $3,357.50 ([2,000 x 58.5 cents] + [3,500 x 62.5 cents]) for the year. You may still have additional allocable interest expense or other non-allocable costs to consider. Actual Expense You had total allocable expenses of $8,250 (including interest) for the same vehicle. The vehicle was used for business purposes for 5,500 miles and used for personal purposes for 1,800 miles. You divide the business use miles by the total miles to determine a BUP of 75.3% (5,500 / 7,300 miles). Your deductible expenses are $6,212.25 ($8,250 x 75.3%). You do not have additional allocable interest expense to consider (but may have other non-allocable costs). 11 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 a. Special rules for lease payments If you lease a vehicle for 30 days or more, a portion of your allocable and deductible business lease payments may be subject to the lease inclusion rules. You may need to reduce your business portion of the lease payment deduction by the lease inclusion amount. Your lease inclusion amount is determined in part by what type of vehicle you are renting, the vehicle’s BUP, the fair market value of the vehicle at the time the lease commenced, what date the lease commenced and will end, and what year of the lease you are currently in. See the Example under Chapter 4 “Leasing a Car” as listed in IRS Publication 463, Travel, Gift, and Car Expenses for an example of calculating a lease inclusion amount. For additional assistance, consult your tax advisor. You may include allocable vehicle expenses during the period in which the vehicle is not being rented as long as it is actively being held out for rent. This applies to the periods between rentals, as well as to the period during which a vehicle is being marketed as a rental for the first time. The IRS can disallow these deductions if you are unable to show you were actively seeking a profit and had a reasonable expectation of achieving one. The deduction cannot be disallowed just because your vehicle is difficult to rent. Should the IRS determine that your rental activity was not engaged in an active attempt to seek a profit, it may recharacterize your rental activity as a hobby. The hobby income/loss reporting rules are complex. Please consult your tax advisor if this becomes the case. II. Additional non-allocable expenses Regardless of the method used to determine your share of vehicle expenses, you are permitted to deduct in full non-allocable expenses that are entirely related to the business use of the vehicle. Examples of these include: Miscellaneous items such as beach chairs, child car seats, beach umbrellas, water bottles, and breath mints that are provided to drivers for a fee or as a convenience Unreimbursed parking or tolls incurred during rental use Note: In the earnings and tax summary provided by Turo, do not include as income or deduct any items listed or related to the “reimbursements” section of the summary. Example: As part of your listing, you offer beach chairs, towels, and a tent for an additional fee of $10/day. During the rental period, your driver incurs a $50 of parking expenses and $40 of tolls, which are billed directly to you. Turo reimburses you for $40 of tolls as outlined in your earnings and tax summary. You would be able to deduct the cost of the beach chairs, towels, and tent in full as business expenses. In addition, you would be able to deduct the $50 of parking expenses. The $10/day rental fee is already included in your gross rental income. The $40 of reimbursed tolls is neither included in your gross income nor deductible by you. 12 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 III. Turo fees A component of fees that Turo charges to you includes protecting your vehicle (the “Protection Plan”) during its business use (i.e., rental) periods. For Hosts who use the Standard Mileage Rate method of computing net rental income, deduct only a percentage of the Turo fees as listed on your earnings and tax summary. 70% can be a reasonable deductible estimate. Note: Recall that under the Standard Mileage Rate method, insurance expense has already been factored and included in the Standard Mileage rate, so the fees that Turo charges you for protection cannot be double-deducted on your tax return (hence, you only deduct 70% of the Turo fees). For drivers who use the Actual Expenses method, deduct 100% of the Turo fees as listed on your earnings tax summary. Note: Under the Actual Expenses method, Turo’s protection is attributable solely to your vehicle’s business use, and would therefore be 100% deductible as a non-allocable expense. Example: Your Turo earnings and tax summary shows Turo fees of $1,100. If you are using the Standard Mileage Rate method, you can deduct $770 ($1,100 x 70%) of such fees in computing taxable income. If you are using the Actual Expenses method, you can deduct $1,100 of such fees in computing taxable income. IV. Repairs and maintenance vs. improvements – deduct or capitalize In general, expenses incurred to repair and maintain your vehicle are deductible as repairs and maintenance expenses (oil changes, replacement of windshield wipers, etc.). With that said, in certain instances amounts paid may rise to an improvement to your vehicle (replacement of major components such as the engine, etc.) that must be capitalized. If you incur costs for work performed on your vehicle, it is best to consult your tax advisor for the tax treatment of any costs incurred. V. Depreciation Vehicle owners can recover the purchase cost of their vehicles attributable to business use through yearly tax deductions. These deductions are called depreciation. Depreciation is a non-cash deduction since it does not represent an actual outflow of money. Five factors determine how much depreciation you can deduct each year: (1) your business use percentage (“BUP”), (2) your basis in your vehicle, (3) the recovery period of the vehicle, (4) the depreciation method used, and finally, (5) the depreciation convention used. (1) Your business use of your vehicle is the mileage your vehicle is driven for business, as opposed to personal, purposes. This use is generally determined as a percentage of your overall use. (2) Your basis in your vehicle is generally the purchase price of the vehicle, plus any registration fees and other costs you incurred. Legal fees, documentation fees, recording fees, and transfer taxes are examples of other costs you need to add to your basis of the property. Note: Your basis in your vehicle may need to be adjusted if any credits were taken when the vehicle was purchased (e.g., electric vehicle tax credits). Please consult your tax advisor if this situation applies to you. 13 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 Note: If you purchased a vehicle in a previous tax year, and placed it in service for business use the first time in a different tax year, your basis in the vehicle is the lower of the fair market value on the date you placed it in service for business or the original basis (i.e., the original purchase price). You may still be able to take bonus depreciation on the vehicle, but you cannot take a Section 179 deduction. (3) The recovery period for vehicles represents the number of years over which you will depreciate your vehicle and claim a depreciation expense. For vehicles, your recovery period is 5 years (or 60 months). The recovery period starts when the property is placed in service. Note that a 5-year recovery period is actually deducted on 6 years of consecutive tax returns since the year 1 and year 6 expenses include a fraction of a year’s worth of depreciation. Example: You acquire a vehicle that you own in year 1 and place into service in year 1. The vehicle has a recovery period of 5 years. Depreciation of the vehicle starts in year 1 and will continue until year 6, when the vehicle is fully depreciated. (4) The current depreciation method used for tax purposes is called the Modified Accelerated Cost Recovery System (“MACRS”). Under MACRS, vehicles are able to be depreciated under the straight-line (“SL”) or declining balance (“DB”) method. The SL method means you depreciate your vehicle pro rata over the years of the recovery period. The DB method allows you to accelerate the depreciation deductions during the earlier years of your vehicle’s life. Note: If the BUP of your vehicle is 50% or less, you must use the SL method under the 5-year MACRS recovery period. (5) In addition to choosing a depreciation method, you must determine a depreciation convention. There are two conventions available: half-year (“HY”) or mid-quarter (“MQ”). Unlike depreciation methods, your depreciation convention is not a choice, but a factual test. If 40% of the total depreciable basis of your MACRS property was placed in service during the last 3 months of the tax year, then all your MACRS property (including your vehicle) is subject to the mid-quarter convention. If not, you are subject to the half-year convention. Note: The rules for determining convention become more complicated if Turo income is not your only business (as the convention test looks at the depreciable basis of all your businesses), or if you have other types of depreciable property, such as residential or non-residential real property, or property placed in service and disposed in the same year. If you are unsure as to which convention applies to you, consult your tax advisor. IRS Publication 946, Appendix A Chart 1 provides a MACRS Percentage Table Guide that provides each year’s depreciation deduction (reflected as a percentage of the depreciable basis placed in service in year 1 under each method and convention). Example 1: You purchased your vehicle in cash on June 1, 2022 for $32,000. The vehicle was your only asset purchased for the year that was used in a trade or business. As part of the purchase, you paid legal and registration fees of $2,000. You started renting out the vehicle immediately after your purchase. The BUP for the year is 35%. The depreciable basis of your vehicle is $34,000 (purchase price of $32,000 plus other costs of 14 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 $2,000). Since the vehicle is the only asset purchased during the year used in a trade or business, you are subject to the HY convention. Since the BUP is 50% or less, you are required to use the SL method to compute your depreciation deduction. Based off IRS Publication 946, Appendix A, Chart 1, the depreciation percentage to apply in the first year of the vehicle’s recovery period using the HY convention and SL method is 10% (Table A-8). Your maximum depreciation deduction is $3,400 (10% times $34,000). Note that this amount has not yet factored in the BUP of your vehicle for the tax year or the passenger automobile depreciation limits, as discussed later. In general, DB methods tend to generate larger depreciation deductions in earlier years followed by smaller ones in later years, whereas SL/ADS methods provide equal yearly deductions. Over the course of the vehicle’s recovery period, the depreciation deductions should be the same (without factoring in BUP and passenger automobile depreciation limits). Finally, your vehicle is subject to a maximum amount of depreciation that may be claimed in a given tax year, given the date the vehicle was placed in service. These maximum amounts can be found in IRS Publication 946, How to Depreciate Property. Electric vehicles have separate (higher) limitations. To determine the final deductible amount of depreciation expense in the current year, multiply your vehicle’s BUP by the maximum depreciation allowable for your vehicle based on its year placed in service under the passenger automobile limitations in “Maximum Depreciation Deduction” as listed in IRS Publication 946 [a]. Then, compare that amount [a] to your vehicle’s depreciation deduction as computed under the IRS Publication 946, Appendix A amounts (i.e., without the passenger automobile limitations), multiplied by your vehicle’s BUP [b]. You are permitted to deduct up to [b], as long as it is equal to or smaller than [a]; otherwise, your deduction is limited to [a]. Any amount under [b] that is not recovered in the tax year due to the amount being larger than [a] is subject to potential deduction in a later tax year. Example 2: Your BUP for the vehicle in Example 1 above is 35%. Therefore, your maximum depreciation deduction in year 1 before the application of the passenger automobile limitations is $1,190 (35% x $3,400 depreciation before passenger automobile limitation rules). You look up the maximum depreciation deduction allowable under the passenger automobile limitations in IRS Publication 946. For automobiles placed in service in 2022, the maximum first year depreciation deduction is $11,200 (assume no bonus depreciation is taken). You multiply the maximum deduction within the automobile limits by the BUP to get a maximum depreciation deduction of $3,920 ($11,200 x 35%). Since your depreciation deduction without regard to the automobile limits ($1,190) is smaller than your depreciation deduction with regard to the automobile limits ($3,920), your depreciation deduction is NOT limited. The determination of which depreciation method is more beneficial to you over the life of your vehicle’s planned rental period is complex. In these circumstances, please consult your tax advisor. (6) Section 179 depreciation deduction If your vehicle is used more than 50% for business in the first year it is placed in service, you may be 15 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 eligible to deduct the full purchase price of the vehicle in the first year of service. (7) Special (“bonus”) depreciation deduction If your vehicle is used more than 50% for business in the first year it is placed in service, you may be eligible to deduct the full purchase price of the vehicle in the first year of service (after claiming any applicable Section 179 deductions). Note: Taxpayers are still required to allocate their Section 179 and bonus depreciation expenses based on the BUP of their vehicles. The rules for determining when it is acceptable to use the Section 179 and special bonus depreciation amounts are extremely complex. Please consult your tax advisor for additional details. 6. Limit on rental losses If you incur more rental expenses than your rental income, you have a loss from your rental activity. Three sets of rules may limit the amount of losses you can deduct. You must consider these rules in the order shown below. For purposes of this guide, we will treat each vehicle you rent as a separate activity. The rules for grouping multiple vehicles under the at-risk and passive activity aggregation rules are complex. For additional details, please consult your tax advisor. I. At-risk activity limits This rule is applied first if there is investment in your vehicle for which you are not at risk. In most cases, any loss from an activity subject to the at-risk rules is allowed only to the extent of the total amount you have at risk in the activity at the end of the tax year. You are considered “at risk” in an activity to the extent of cash provided and the adjusted basis of the vehicle you contributed to the activity. You are also considered at risk for any portion of debt for which you are personally liable or pledged other property as security which has a fair market value equal to or greater than the borrowed amount. Example 1: You pay $40,000 cash to acquire a vehicle. Your at-risk basis in the vehicle is $40,000. Example 2: You pay $5,000 cash and borrow $35,000 to acquire the same $40,000 vehicle. In case of default, you would not be personally liable for any uncollectible portion of the loan (i.e., the only recourse the lender has is to repossess the car), nor have you pledged other property as security for the loan. Your at-risk basis in the activity is $5,000. Example 3: You pay $5,000 cash and borrow $35,000 to acquire the same $40,000 vehicle. In case of default, you would be personally liable for any uncollectible portion of the loan. Your at-risk basis in the activity is $40,000. Paying off a loan, becoming personally liable for the loan, or pledging other property with a fair market value equal to or greater than the balance of the loan also increases your at-risk amount. Likewise, refinancing the loan such that you become no longer personally liable for the loan, or removing a pledge of other property as security for the loan reduces your at-risk amount. If you have a situation where you are subject to the at-risk rules, see Form 6198 and IRS Publication 925. The rules for reporting at-risk limitations are complex. For further assistance, consult your tax advisor. 16 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 II. Passive activity limits Once you have determined what amount of your rental activity you are considered at risk for, you must apply the passive activity limits. Generally, your rental activity will be considered a passive activity, unless you can demonstrate that you materially participated in the rental activity (see section 8). Losses generated from passive activities can only offset other sources of passive income. Example 1: You determine that your vehicle generated a passive activity loss of $2,400 for the current tax year. You have no other source of passive income to report. Your $2,400 loss is non- deductible and carries forward as a passive activity loss. Example 2: In the subsequent year, your vehicle generates another $2,400 passive activity loss. However, you have $5,000 of other passive income from a separate activity. You report $200 of net income in the current tax year (since current year passive income exceeds current year and prior year suspended passive losses). Note: Losses disallowed due to the at-risk rules and passive activity limits are carried forward indefinitely until they can be used to offset net rental income in future years. In the year you dispose of your vehicle, you may be eligible to deduct any prior year suspended losses. If you have a situation where you are subject to the passive activity loss rules, see Form 8582 and IRS Publication 925. Please consult your tax advisor on the application of these loss limitations to your activities. III. Excess business loss Although exceedingly rare, it is possible that your rental activity loss may still be partially disallowed under the “excess business loss” provisions. Please consult your tax advisor for further information. 7. Self-employment income and qualified business income (“QBI”) Self-employed persons are persons who are in business for themselves. In addition to owing regular income tax on your earnings, you may also be subject to self-employment tax as well. Self-employment income is reportable on Form Schedule SE – Self-Employment Tax (Form 1040). For more information on whether you would be subject to the self-employment tax reporting rules, consult your tax advisor. Qualified business income (“QBI”) is income generated in the United States through certain “qualified trade or business” activities. Income from certain activities may be eligible to take a 20% deduction on QBI, subject to certain limitations. The application and determination of the QBI rules are extremely complex. For more information, refer to Form 8995-A and the instructions therein and consult your tax advisor. 8. How to report rental income and expenses Most individual taxpayers report rental income and expenses as a “non-material” participant on Form Schedule 1 (Form 1040). Use Schedule 1, line 8(l) to report your gross receipts from box 1(a) per your Turo-provided Form 1099-K. Use Schedule 1, use line 24(b) to report your deductible expenses. See Exhibits A and B for an example of Schedule 1 (Form 1040), Pages 1 and 2. 17 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 Some individuals may meet the threshold of “material participant” and report rental income and expenses on Form Schedule C (Form 1040). Use Schedule C, line 1 to report gross receipts from box 1(a) from your Turo-provided Form 1099-K. Use Schedule C, lines 8–27(a) to report your deductible expenses. See Exhibit C for an example of Schedule C (Form 1040). The determination of whether you are a material or non-material participant is extremely complex and highly fact specific. Please consult your tax advisor if you have any questions. If you have a loss from your rental income activity, you also may need to complete one or both of the following forms. These forms will need to be completed year over year to keep track of disallowed loss due to at-risk rule or passive activity limit. Form 6198, At-Risk Limitations. See At-risk activity limits, earlier. Form 8582, Passive Activity Loss Limitations. See Passive activity limits, earlier. 9. Reporting payments to independent contractors If you make $600 or more in payments to independent contractors for services performed on your vehicle (e.g., cleaning services from a third party), you are required to issue Form 1099-NEC to the independent contractors and submit a copy to the IRS. See IRS instructions on how to complete Form 1099-NEC. 10. How is (net) rental income taxed? (federal) For federal income tax purposes, net rental income is taxed at ordinary income tax rates, subject to the limitations discussed above. Ordinary income tax rates vary, depending on your filing status and overall income levels. See Exhibit D for 2022 ordinary income tax rates for individual taxpayers. 11. Quarterly estimated tax payments Estimated taxes is the method used to pay tax on rental income not subject to withholding. If you do not pay enough tax through withholding or estimated tax, you may be subject to a penalty. Please consult your tax advisor for more details on your specific circumstances. 12. Sale of vehicle used as rental property Upon the sale of your vehicle, you must determine whether you have a taxable gain or a loss. The rules for computing your taxable gain and loss, as well as reporting it, are complex. Please consult your tax advisor. 13. Documents to be retained All supporting documentation with respect to rental income and expenses must be kept for tax purposes regardless of the length of the rental period. You do not need to submit the supporting documentation with your return. However, the IRS may request copies of the documentation. You should keep a record of the following: Receipts for all deductible expenses, including repairs, supplies, cleaning services, etc. Your Turo-provided Form 1099-K and earnings and tax summaries Vehicle purchase/lease contracts (including details regarding any financing) 18 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 Your vehicle odometer logs Carryforward of passive activity losses not utilized in prior years Form 1099-NEC issued to independent contractors Generally, you must keep records that support items shown on your return until the period of limitations for that return runs out. The period of limitations is the period of time during which you can amend your return to claim a credit or refund or the IRS can assess additional tax. If you: Then the period of limitation is: (a) Owe additional tax and (b), (c), and (d) do not apply to you 3 years (b) Do not report income that you should and it is more than 6 years 25% of the gross income shown on your return (c) File a fraudulent return No limit (d) Do not file a return No limit The later of 3 years or 2 years after tax (e) File a claim for credit or refund after you filed your return was paid (f) File a claim for a loss from worthless securities 7 years Additionally, you should keep records relating to your basis in your vehicle until the period of limitations expires for the year in which you dispose of the vehicle. You must keep these records to figure any depreciation deduction and to figure the gain or loss when you sell or otherwise dispose of the property. If you do not keep the requisite records, it may be impossible for you to prove that you incurred deductible expenses or to establish your basis for gain or loss. Without such proof, the IRS can deny you a deduction. When your records are no longer needed for tax purposes, do not discard them until you check to see whether you have to keep them longer for other purposes. For example, your insurance company or creditors may require you to keep them longer than the IRS does. 14. Other resources Below is a list of resources that you can reference for a more thorough explanation on the topics discussed above. IRS Guidance and Publications: Business Use of a Car: https://www.irs.gov/taxtopics/tc510 IRS issues standard mileage rates for 2022: https://www.irs.gov/newsroom/irs-issues-standard-mileage- rates-for-2022 IRS increases standard mileage rate for remainder of 2022: https://www.irs.gov/newsroom/irs-increases- mileage-rate-for-remainder-of-2022 IRS Publication 463, Travel, Entertainment, Gift, and Car Expenses: https://www.irs.gov/publications/p463 19 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
Turo | General guidance on the taxation of business income January 2023 Recordkeeping: https://www.irs.gov/taxtopics/tc305 IRS Publication 925 (2022), Passive Activity and At-Risk Rules: https://www.irs.gov/pub/irs-pdf/p925.pdf IRS Publication 946 (2022), How to Depreciate Property: https://www.irs.gov/pub/irs-pdf/p946.pdf Form 8995-A Qualified Business Income Deduction: https://www.irs.gov/pub/irs-pdf/f8995a.pdf Self-Employment Tax (Social Security and Medicare Taxes): https://www.irs.gov/businesses/small- businesses-self-employed/self-employment-tax-social-security-and-medicare-taxes Instructions for Forms 1099-MISC and 1099-NEC: https://www.irs.gov/instructions/i1099mec 20 Disclaimer This documentation is intended solely for information purposes and no Turo Host or other third party may rely upon it as tax or legal advice or use it for any other purpose. As such, EY and Turo assume no responsibility whatsoever to Turo Hosts or other third parties as a result of the use of information contained herein. This documentation was prepared by EY, and does not necessarily reflect the views of Turo. Please refer to the disclaimer on page 1 for more information.
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