As the tax filing deadline approaches, we will be discussing tax-planning tips and other tax related issues. In this post, we will outline a process to determine which account(s) should bear advisory fees by calculating the method that yields the greatest income tax benefit for the client. Hence, if you are a fee-based or fee-only advisor, this information will provide you with a process to guide you in your fee deductions.
IRS Rules on Deducting Advisory Fees
1) IRA fees may be deducted from a taxable account (i.e., joint or single).
2) Fees on a taxable account may not be deducted from an IRA.
3) Fees deducted from an IRA are not tax deductible on IRS Form 1040; Schedule A (i.e., itemized deductions).
4) Advisory fees are a Tier II deduction and as such, are deducted on IRS Form 1040, Schedule A. The aggregate of Tier II deductions are deductible to the extent they exceed 2% of the taxpayers AGI.
5) This is not an IRS rule or law, but it’s best not to deduct Roth IRA fees from a Roth account. Making fewer fee deductions from a Roth will result in greater earnings that will eventually be withdrawn tax-free.
Here is an example to illustrate the process of determining the most tax beneficial method of deducting advisory fees.
- Client: Husband and Wife
- Annual Advisory Fee %: 0.65%
- Assets Under Management:
- Joint Account: $1,000,000
- Husband’s IRA: $400,000
- Wife’s IRA: $250,000
- Total Assets: $1,650,000
- Fees by Account (FMV x 0.65%)
- Joint Account: $6,500
- Husband’s IRA: $2,600
- Wife’s IRA: $1,625
- Total Fee: $10,725
- Taxpayer’s AGI: $350,000
- Schedule A, Tier II Deduction Threshold: $7,000 ($350,000 x 2%)
- Advisory fees are the clients only Tier II deductible item
- Marginal Tax Bracket: 35%
- Effective Tax Bracket: 29%
A) Deduct advisory fees from the applicable account
B) Deduct all fees from joint account
In this scenario, each account bears its own fee. Because the fee on the joint account ($6,500) is less than 2% of their AGI ($7,000), and because fees deducted from an IRA are not deductible on IRS Form 1040, Schedule A, no income tax deduction is allowed.
However, there is an inherent tax benefit since fees deducted from an IRA are not subject to income tax. Thus, the tax benefit is as follows: