IRS Logo
Print - Click this link to Print this page

Information Document Request for Interchange and Merchant Discount Fees - Banks

Interchange and Merchant Discount fees can be illustrated by a typical 4-party transaction involving the purchase of an item using a typical VISA/MasterCard type general-purpose credit card issued by a bank.  When a Cardholder purchases a $100 item from a Merchant using a typical VISA/MasterCard type credit card, the Merchant passes on the $100 charge to its Merchant/Acquiring Bank in exchange for $98.00, pursuant to the Merchant’s contract with the Merchant/Acquiring Bank.  The Merchant/Acquiring Bank submits the $100 charge into the VISA/MasterCard system and receives $98.50 from the customer’s credit card Issuing Bank (less a small processing VISA/MasterCard fee) in accordance with the VISA/MasterCard rules.  The Issuing Bank eventually receives $100 from the Cardholder when the credit card charge is paid.  Under this scenario, the Merchant/Acquiring Bank keeps a net “Merchant Discount” fee of $.50 ($98.50 - $98.00), while the Issuing Bank receives an “Interchange" fee of $1.50 ($100 - $98.50).  These fees combined are sometimes referred to as a “Merchant Discount” fee.  In some instances, the structure of the transaction changes slightly, but the ultimate economic effect is the same.  In addition, the same entity may act as both the Issuing Bank and the Merchant/Acquiring Bank in the same transaction. 

With the above description in mind, please provide the following information:

I.  Please identify each entity in the consolidated group that acted as an Issuing Bank, a Merchant/Acquiring Bank or both during the years under examination, along with the years each entity acted in which capacity.

II.  For each entity identified above, please respond to the following questions to the extent applicable for each year under examination:

A. In General:


1. Please provide the differences, if any, between how income from the following fees was reported for book and tax purposes for each year under examination:

a) Interchange or similar fees  
b) Merchant Discount or similar fees

2. Please provide schedules illustrating how income from the following fees was computed for book and tax purposes for each year under examination:

a) Interchange or similar fees  
b) Merchant Discount or similar fees

3. Please provide a list of all accounts used to record revenue and expenses, including Original Issue Discount (OID), for credit cards, debit cards and Merchant/Acquiring Bank activities.

4. How are Interchange or similar fees determined for all credit card and debit card transactions processed through the VISA and/or MasterCard system – Were fees determined based on average credit risk, volume of business, payment history of customers, etc.?

5. How are Interchange or similar fees determined for all other credit and debit cards, which do not clear through the VISA and/or MasterCard processing system – Were fees determined based on average credit risk, volume of business, payment history of customers, etc.?

6. Please provide copies of any agreements with VISA and/or MasterCard in effect during the years under examination.

7. How are Merchant Discount or similar fees determined for all credit card and debit card transactions – Were fees determined based on Interchange fees or whether a credit or debit card was utilized for the purchase?

B. Accounting Method:

1. Did the entity file a Form 3115 for any credit card fees, debit card fees, Interchange fees, Merchant Discount fees or similar fees based upon the application of IRC § 1272(a)(6)(C)(iii) dealing with “any pool of debt instruments the yield on which may be affected by reason of prepayments”?

a) If yes, for which taxable years were the Form(s) 3115 filed?
b) Please furnish copies of all Form(s) 3115 filed involving IRC § 1272(a)(6).

2. Please reconcile the difference, if any, between the IRC § 481(a) adjustment reflected on the Form(s) 3115 filed and the amount reflected in the tax return filed for the year of change (and for any amended tax return filed for the year of change).

3. Has the entity made any modifications, alterations, refinements, etc. to either the methodology or the type of transactions incorporated into the methodology used to compute the amount of deferral under  IRC § 1272(a)(6) in any intervening/subsequent filed tax return?  If so, please explain.


C.  Issuing Bank Activities - Credit Card Transactions:


1. If the entity acted as an Issuing Bank during the years under examination, what type of credit cards (e.g. VISA) did the entity issue during each year under examination?

2. Please provide representative samples of the credit card agreements in effect with Cardholders, including all related amendments, for each type of credit card issued during the years under examination.

3. Please list all standard journal entries associated with a single credit card transaction for each type of credit card issued during the years under examination.

4. How much of the Interchange or similar fees related to credit card transactions were accrued and included in book income for each of the years under examination?

5. Did the entity defer credit card Interchange or similar fees under IRC § 1272(a)(6) or another authority for tax purposes for the years under examination?  If so, please specify the amount of the deferral and the authority for each of the years under examination.

6. Please provide the differences, if any, between how the Interchange or similar fee income from credit card transactions was reported for book and tax purposes for each year under examination.

7. Please provide schedules showing all Schedule M entries for Interchange or similar fees related to credit card transactions for each year under examination.  These schedules should include the current portion of the Schedule M adjustment, the amount from prior years being “accreted” in the current year, and rollover adjustments due to prior IRS examinations. 

D.  Issuing Bank Activities - Debit Card Transactions:


1. If the entity acted as an Issuing Bank during the years under examination, what type of debit cards (e.g. VISA) did the entity issue during each year under examination?

2. Please provide representative samples of the debit card agreements in effect with Cardholders, including all related amendments, for each type of debit card issued during the years under examination.

3. Please list all standard journal entries associated with a single debit card transaction for each type of debit card issued during the years under examination.

4. How much of the Interchange or similar fees related to debit card transactions were accrued and included in book income for each of the years under examination?

5. Did the entity defer debit card Interchange or similar fees under IRC § 1272(a)(6) or another authority for tax purposes for the years under examination?  If so, please specify the amount of the deferral and the authority for each of the years under examination.

6. Please provide the differences, if any, between how the Interchange or similar fee income from debit card transactions was reported for book and tax purposes for each year under examination.

7. Please provide schedules showing all Schedule M entries for the Interchange or similar fees related to debit card transactions for each year under examination.  These schedules should include the current portion of the Schedule M adjustment, the amount from prior years being “accreted” in the current year, and rollover adjustments due to prior IRS examinations.


E.  Merchant/Acquiring Bank Activities:

1. Did the entity act as a Merchant/Acquiring Bank during the years under examination?

2. Please provide representative samples of contracts with Merchants setting Merchant Discount or similar fees when a credit or debit card was used for purchases, including all of the related amendments, that were in effect during the years under examination.

3. How much of the Merchant Discount or similar fees related to both credit and debit card transactions were accrued and included in book income for each of the years under examination?

4. Did the entity defer Merchant Discount or similar fees under I.R.C. § 1272(a)(6) or another authority for tax purposes for the years under examination?  If so, please specify the amount of the deferral and the authority for each of the years under examination.

5. Please provide the differences, if any, between how the Merchant Discount or similar fee income from both credit and debit card transactions was reported for book and tax purposes for each year under examination.

6. Please provide schedules showing all Schedule M entries for the Merchant Discount or similar fees related to both credit and debit card transactions for each year under examination.  These schedules should include the current portion of the Schedule M adjustment, the amount from prior years being “accreted” in the current year, and rollover adjustments due to prior IRS examinations.

7. Does the entity process any transactions in which it acts as both the Issuing Bank and the Merchant/Acquiring Bank?  If so, please explain the differences, if any, as to how these transactions are processed as compared to transactions in which the entity acts as only the Issuing or Merchant/Acquiring Bank.

 


IDR Discussed with Taxpayer:   _________________________                  
Response Date: _________________
Receipt acknowledged By Company: __________________
                                                             (Initials)               (Date)
Date received by Examination Team: ___________________
                                                                (Initials)     (Date)

Page Last Reviewed or Updated: 21-Nov-2014