Both the Market Facilitation Program (MFP) and the Coronavirus Food Assistance Programs (CFAP) have Adjusted Gross Income (AGI) limits of $900,000 per entity / per individual. However, if both the entity and each individual owner (if applicable) have at least 75% of its income from farming, then unlimited AGI is allowed.
However, the FSA will require the producer to sign off on Form CCC-942 and as part of that requirement is a CPA or attorney to “attest” to this certification. However, CPAs should not sign this form. But the FSA still requires the CPA or attorney to affirm this 75% level. What can the CPA do instead?
The AICPA in conjunction with the Farm Service Agency worked on coming up with a letter that a CPA or attorney could write that would meet the AICPA standards in regards to the normal AGI certification. The FSA last year updated this letter to apply for the more than 75% of AGI from farming. This allows the CPA or attorney to prepare this letter instead of signing the Form CCC-942.
The sample letter is in the FSA Handbook 5-PL starting on page 6-69.
If your client asks you to sign this form, make sure to work up the letter instead.
