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B-167459 1 (1978-02-23)

handle is hein.gao/gaobadtgt0001 and id is 1 raw text is: 


865


        COMPTROLLER GENERAL OF THE UNITED STATES
                 WASHINGTON, D.C. 20548


B-167459


FEB 2 3 1978


Mr. Thomas .G. Cassidy
•Chairman, ASPR Committee
Office -of the Assistant
  'Secretary of Defense
Department .of Defense

Dear Mr. Cassidyi

    By letter dated September 2.8, 197.7, with attachment,
you transmktted for our comment proposed revisions to-
ASPR 15-205,6(f), regarding Compensation for Personal
Services.

    Currently, under ASPR 15-205.6, deferred compensation
costs are allocable and allowable only in those years in
which they are allowable as tai deductions under the
Internal Revenue Code,. Generally such costs are allowa-
'ble as tax deductions only in the years- in which the
employees ar-e actually paid. TherefOre, under current
ASPR policy, deferred compensation costs are neither allo-
cable nor -allowable in the year of award to the employeel
rather, they are allocable to and allowable in the years
in which actual payments are made. Conversely, Cost
Accounting Standard (CAS).415 sets forth measurement
and allocability criteria based on accrual accountina
concepts and prescribes that deferred compensation costs
are allocable entirely to the year in which the award is
made to the employee--they are not allocable to the years
subsequent to award in which actual payments are made.
In view of the above conflict, the ASPPRCommittee is
considering a revision to the cited AkPR provision,
incorporating CAS 415.

    The proposed revision makes subparal.raphs (A) and (B)
of ASPR i5-205.6(f)(2)(iI) applicable only to deferred
compensation costs not covered by CAS 415. The first
phrase of each of these subparagraphs .requires deferred
compensation costs to be deductible for the same fiscal
year for Federal Income tax purposes under Section 404
of the Internal Revenue Code of 1954. We agree that
subparagraphs (A) and (?) should no longer be applicable
to costs covered by CAS 415.


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