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Summer hours are in effect: Our offices close at NOON on Fridays from May 17th to July 12th
Our offices will be closed on December 24, December 25, and January 1.
Friday, December 27, is the last day of our winter hours, with offices closing at noon MST.
Summer hours are in effect: Our offices close at NOON on Fridays from May 17th to July 12th
Our offices will be closed on December 24, December 25, and January 1.
Friday, December 27, is the last day of our winter hours, with offices closing at noon MST.
Colorado Springs, Colo. – Stockman Kast Ryan + Co, LLP (SKR+CO), the largest locally-owned certified public accounting firm in Southern Colorado, is pleased to announce that Senior Tax Manager Buddy Newton was recognized as one of this year’s 40 Under Forty Honorees by the National Association of Certified Valuators and Analysts® (NACVA®).
NACVA’s® 40 Under Forty program recognizes the nation’s emerging visionary leaders across all spectrums of the accounting and financial consulting professions. The honorees embody the drive, motivation and courage needed to lead the industry’s next generation.
Since joining public accounting in 2008, Buddy has risen to manager-in-charge of over 100 client relationships with a specialty practice in business valuations, expertise in the construction and auto dealership industries and a wealth of experience advising high-net-worth individuals. Buddy handles the firm’s valuation engagements, successfully demonstrating the benefits for young professionals to get involved in the valuation world and encouraging coworkers to pursue their CVA® designation.
For more information or to schedule an interview with Chanda Chuon, manager of marketing media and strategic partnerships, please contact 801.486.0600 or schandac1@nacva.com.
About Stockman Kast Ryan + Co.
Stockman Kast Ryan + Co, LLP (SKR+CO) is Southern Colorado’s largest Certified Public Accounting firm providing a variety of in-depth business services. Tax services for individuals include businesses, fiduciaries and not-for-profit organizations, audit and accounting services. SKR+CO also offers outsourced accounting and bookkeeping services – customized to clients’ needs – estate planning, small/emerging business advisory services, contract chief financial officer services, business valuations and litigation support services. SKR+CO is a member of DFK International/USA, a worldwide association of independent firms. For more information on SKR+CO visit www.skrco.com.
Inside Public Accounting (IPA) presented its first ranking of the nation’s TOP 300 accounting firms—the only one of its kind. Stockman Kast Ryan + Co, LLP (SKR+CO), the largest locally-owned certified public accounting firm in Southern Colorado, has been named one of seven recipients of the inaugural Excellence in Firm Culture awards.
The award is based on the results of an assessment of 2,000 staff members and recognizes firms demonstrating excellence in 12 core qualities of culture as determined by third-party culture experts, CultureIQ.
“I’m so excited about this particular recognition because culture is an expression of our collective values, daily interactions and general environment,” SKR+CO Managing Partner Trinity Bradley-Anderson stated. “The survey results conveyed the trust, respect and appreciation that we each try to demonstrate every day at Stockman Kast Ryan + Company.”
The 12 core qualities measured in the Culture Assessment: Agility; Alignment; Collaboration; Customer Centricity; Empowerment; Engagement; Growth Development; Innovation; Quality; Recognition and Rewards; Trust and Integrity, and Work-life Balance.
IPA Excellence in Firm Culture award winners achieved at least 75% of the total possible score in the combined 12 core culture qualities as well as a minimum of 75% of the total possible employee Net Promoter Score.
IPA also considered the firms’ employee Net Promoter Scores (eNPS) in determining the winners. According to CultureIQ, the eNPS captures a snapshot of employees’ willingness to be ambassadors for the company by advocating employment there.
About Stockman Kast Ryan + Company
Stockman Kast Ryan + Co, LLP (SKR+CO) is Southern Colorado’s largest certified public accounting firm providing a variety of in-depth business services. Tax services for individuals include businesses, fiduciaries and nonprofit organizations, audit and accounting services. SKR+CO also offers outsourced controller and contract CFO services as well as accounting and bookkeeping services – customized to clients’ needs, estate planning, small/emerging business advisory services, business valuations and litigation support services. SKR+CO is a member of DFK International/USA, a worldwide association of independent firms. For more information on SKR+CO visit skrco.com.
About INSIDE Public Accounting
The Platt Group, based in Indianapolis, was founded in 2006 and is a highly regarded independent publication was formerly known as Bowman’s Accounting Report. IPA publishes two award-winning publications: the IPA newsletter and the annual IPA National Benchmarking Report, along with in-depth reports focused on IT, HR and firm administration. For more information, visit www.insidepublicaccounting.com.
Colorado Springs, Colo. – Stockman Kast Ryan + Co, LLP (SKR+CO), the largest locally-owned certified public accounting firm in Southern Colorado, announces ten professional staff promotions:
Audit Department
Courtney has a Bachelor of Science in accounting from Adams State University and a Master of Accounting from University of Washington, Tacoma. She has been in public accounting since 2017.
Katie has a Bachelor of Science in Accounting from Marquette University and a Master of Accounting from University of North Carolina, Chapel Hill. She has been in public accounting since 2017.
Rob has a Master of Accounting from University of Colorado, Colorado Springs. He has been in public accounting since 2017.
Tax Department
Amy has a Bachelor of Accounting from Columbus State University and has been in public accounting since 2006.
Grant has a Bachelor of Accounting from University of Colorado, Colorado Springs and has been in public accounting since 2017.
James has a Bachelor of Science in Business with Emphasis in Accounting and Finance from University of Colorado, Colorado Springs and a Master of Business Administration with Emphasis in Accounting from University of Colorado, Colorado Springs. He has been in public accounting since 2016.
Jennifer received her bachelor’s from Columbia College and has her Master of Business Administration with Emphasis in Accounting from University of Colorado, Colorado Springs. She has been in accounting since 2018.
Jessica has a Bachelor of Science in Accounting from University of Colorado, Colorado Springs and has been in public accounting since 2017.
Justin has a Bachelor of Science in Accounting from University of Colorado, Colorado Springs and has been in public accounting since 2018.
Ramses has a Bachelor of Science in Accounting from University of Colorado, Colorado Springs and has been in public accounting since 2017.
About Stockman Kast Ryan + Co
Stockman Kast Ryan + Co, LLP (SKR+CO) is Southern Colorado’s largest certified public accounting firm providing a variety of in-depth business services. Tax services for individuals include businesses, fiduciaries and nonprofit organizations, audit and accounting services. SKR+CO also offers outsourced accounting and bookkeeping services – customized to clients’ needs – estate planning, small/emerging business advisory services, contract chief financial officer services, business valuations and litigation support services. SKR+CO is a member of DFK International/USA, a worldwide association of independent firms. For more information on SKR+CO visit skrco.com.
Bitcoin and other forms of virtual currency are gaining popularity worldwide. Yet many businesses, consumers, employees and investors are still confused about how they work and how to report transactions on their federal tax returns. The IRS recently announced that it is reaching out to taxpayers who potentially failed to report income and pay tax on virtual currency transactions or did not report them properly.
The nuts and bolts
Unlike cash or credit cards, small businesses generally don’t accept bitcoin payments for routine transactions. However, a growing number of larger retailers and online businesses now accept payments. Businesses can also pay employees or independent contractors with virtual currency. The trend is expected to continue, so more small businesses may soon get on board.
Virtual currency has an equivalent value in real currency and can be digitally traded between users. It can also be purchased and exchanged with real currencies (such as U.S. dollars). The most common ways to obtain virtual currency like bitcoin are through virtual currency ATMs or online exchanges, which typically charge nominal transaction fees.
Tax reporting
Virtual currency has triggered many tax-related questions. The IRS has issued limited guidance to address them. In 2014, the IRS established that virtual currency should be treated as property, not currency, for federal tax purposes.
As a result, businesses that accept bitcoin payments for goods and services must report gross income based on the fair market value of the virtual currency when it was received. This is measured in equivalent U.S. dollars.
From the buyer’s perspective, purchases made using bitcoin result in a taxable gain if the fair market value of the property received exceeds the buyer’s adjusted basis in the currency exchanged. Conversely, a tax loss is incurred if the fair market value of the property received is less than its adjusted tax basis.
Wages paid using virtual currency are taxable to employees and must be reported by employers on W-2 forms. They are subject to federal income tax withholding and payroll taxes, based on the fair market value of the virtual currency on the date of receipt.
Virtual currency payments made to independent contractors and other service providers are also taxable. In general, the rules for self-employment tax apply and payers must issue 1099-MISC forms.
IRS campaign
The IRS announced it is sending letters to taxpayers who potentially failed to report income and pay tax on virtual currency transactions or did nott report them properly. The letters urge taxpayers to review their tax filings and, if appropriate, amend past returns to pay back taxes, interest and penalties.
By the end of August, more than 10,000 taxpayers will receive these letters. The names of the taxpayers were obtained through compliance efforts undertaken by the IRS. The IRS Commissioner warned, “The IRS is expanding our efforts involving virtual currency, including increased use of data analytics.”
Last year, the tax agency also began an audit initiative to address virtual currency noncompliance and has stated that it is an ongoing focus area for criminal cases.
Implications of going virtual
Contact your trusted advisor if you have questions about the tax considerations of accepting virtual currency or using it to make payments for your business. If you receive a letter from the IRS about possible noncompliance, consult with your trusted business advisor before responding.
If your small business doesn’t offer its employees a retirement plan, you may want to consider a SIMPLE IRA. Offering a retirement plan can provide your business with valuable tax deductions and help attract and retain employees. For a variety of reasons, a SIMPLE IRA can be a particularly appealing option for small businesses. The deadline for setting one up for this year is October 1, 2019.
The basics
Unlike cash or credit cards, small businesses generally don’t accept bitcoin payments for routine transactions. However, a growing number of larger retailers and online businesses now accept payments. Businesses can also pay employees or independent contractors with virtual currency. The trend is expected to continue, so more small businesses may soon get on board.
As the employer, you can choose from two contribution options:
1. Make a “nonelective” contribution equal to 2% of compensation for all
eligible employees. You must make the contribution regardless of whether the
employee contributes. This applies to compensation up to the annual limit of
$275,000 for 2018 (annually adjusted for inflation).
2. Match employee contributions up to 3% of compensation. Here, you contribute
only if the employee contributes. This isn’t subject to the annual compensation
limit.
Employees are immediately 100% vested in all SIMPLE IRA contributions.
Employee contribution limits
Any employee who has compensation
of at least $5,000 in any prior two years and is reasonably expected to earn
$5,000 in the current year, can elect to have a percentage of compensation put
into a SIMPLE IRA.
SIMPLE IRAs offer greater income deferral
opportunities than ordinary IRAs, but lower limits than 401(k)s. An employee
may contribute up to $12,500 to a SIMPLE IRA in 2018. Employees age 50 or older
can also make a catch-up contribution of up to $3,000. This compares to $5,500
and $1,000, respectively, for ordinary IRAs, and to $18,500 and $6,000 for
401(k)s.
A SIMPLE IRA might be a good choice for your small business, but it isn’t the
only option. Contact your trusted advisor to learn more about a SIMPLE IRA or
to hear about other retirement plan alternatives for your business.
Contact your trusted advisor with any questions.
Look beyond day-to-day financial management.
Many business owners reach a point where managing the financial side of their enterprise becomes overwhelming. This is usually a good thing; the company has grown to a point where simple bookkeeping and basic financial reporting no longer suffice.
If your business has similarly expanded past its capacity, it may be time to add a chief financial officer (CFO) or controller – on either a full-time or part-time basis. Before taking the leap to hire, consider whether your payroll can take on this high-paying position as a full-time employee, or if hiring a part-time CFO consultant is a better fit. Read more to understand exactly what services you are paying for and what makes the most business sense for your company.
The broad role
The role of a CFO or controller is to look beyond day-to-day financial management to more holistic, big-picture planning of financial and operational goals. CFOs take a seat at the executive table and serve as a higher level of support for all matters related to the company’s finances and operations.
CFOs go far beyond merely compiling financial data. They interpret the data to determine how financial decisions will impact all areas of your business. These individuals can plan capital acquisition strategies, so your company has access to financing, as needed, to meet working capital and operating expenses.
In addition, a CFO or controller will serve as the primary liaison between your company and its bank to ensure your financial statements meet requirements should you require help negotiating any loans. Analyzing possible merger, acquisition and other expansion opportunities also falls within a CFO’s or controller’s purview.
Specific responsibilities
A CFO or controller typically has a set of core responsibilities that link to the financial oversight of your operation. This includes making sure there are adequate internal controls to help safeguard the business from internal fraud and embezzlement.
The hire also should be able to implement improved cash management practices that will boost cash flow and improve budgeting/cash forecasting. They should be able to perform ratio analysis and compare the financial performance of your business to benchmarks established by similar-size companies in the same geographic area. A controller or CFO should analyze the tax and cash flow implications of different capital acquisition strategies — for example, leasing vs. buying equipment and real estate.
Major commitment
Make no mistake, hiring a full-time CFO or controller represents a major commitment in both duration of the hiring process and dollars to your payroll. These financial executives typically command substantially high salaries and attractive benefits packages. Another option is to outsource this role to a part-time or fractional CFO consultant who provides business advisory services for a set amount of time. Starting with a part-time CFO may help you assess your current processes and internal controls, then help your company to transition to a full-time CFO position down the road.
Regardless of the route you choose, contact your trusted advisor to help you assess the financial impact of the idea.
When President Trump signed into law the Tax Cuts and Jobs Act (TCJA) in December 2017, much was made of the dramatic cut in corporate tax rates. But the TCJA also includes a generous 20% qualified business income (QBI) deduction for smaller businesses that operate as pass-through entities, with income that is “passed through” to owners and taxed as individual income.
The IRS issued proposed regulations for the qualified business income (QBI), or Section 199A, deduction in August 2018. Now, it has released final regulations and additional guidance, just in time for the first tax season in which taxpayers can claim the deduction. Among other things, the guidance provides clarity on who qualifies for the QBI deduction and how to calculate the deduction amount.
Rental real estate owners – proposed safe harbor
One of the lingering questions related to the QBI deduction was whether it was available for owners of rental real estate. The latest guidance (found in IRS Notice 2019-07) includes a proposed safe harbor that allows certain real estate enterprises to qualify as a business for purposes of the deduction. Taxpayers can rely on the safe harbor until a final rule is issued.
Generally, individuals and entities that own rental real estate directly or through disregarded entities (entities that are not considered separate from their owners for income tax purposes, such as single-member LLCs) can claim the deduction if:
The 250 hours of services may be performed by owners, employees or contractors. Time spent on maintenance, repairs, rent collection, expense payment, provision of services to tenants and rental efforts counts toward the 250 hours.
Investment-related activities, such as arranging financing, procuring property and reviewing financial statements, do not.
Be aware that rental real estate used by a taxpayer as a residence for any part of the year is not eligible for the safe harbor.
This safe harbor also is not available for property leased under a triple net lease that requires the tenant to pay all or some of the real estate taxes, maintenance and building insurance and fees, or for property used by the taxpayer as a residence for any part of the year.
Aggregation of multiple businesses
It is not unusual for small business owners to operate more than one business. The proposed regs include rules allowing an individual to aggregate multiple businesses that are owned and operated as part of a larger, integrated business for purposes of the W-2 wages and unadjusted basis immediately after acquisition (UBIA) of qualified business property (QBP) limitation, thereby maximizing the deduction. The final regs retain these rules with some modifications.
For example, the proposed rules allow a taxpayer to aggregate trades or businesses based on a 50% ownership test, which must be maintained for a majority of the taxable year. The final regulations clarify that the majority of the taxable year must include the last day of the taxable year.
The final regs also allow a “relevant pass-through entity” — such as a partnership or S corporation — to aggregate businesses it operates directly or through lower-tier pass-through entities to calculate its QBI deduction, assuming it meets the ownership test and other tests. (The proposed regs allow these entities to aggregate only at the individual-owner level.) Where aggregation is chosen, the entity and its owners must report the combined QBI, wages and UBIA of qualified property figures.
A taxpayer who doesn’t aggregate in one year can still choose to do so in a future year. Once aggregation is chosen, though, the taxpayer must continue to aggregate in future years unless there’s a significant change in circumstances.
The final regs generally don’t allow an initial aggregation of businesses to be done on an amended return, but the IRS recognizes that many taxpayers may be unaware of the aggregation rules when filing their 2018 tax returns. Therefore, it will permit taxpayers to make initial aggregations on amended returns for 2018.
UBIA in qualified property
The final regs also make some changes regarding the determination of UBIA in qualified property. The proposed regs adjust UBIA for nonrecognition transactions (where the entity doesn’t recognize a gain or loss on a contribution in exchange for an interest or share), like-kind exchanges and involuntary conversions.
Under the final regs, UBIA of qualified property generally remains unadjusted as a result of these transactions. Property contributed to a partnership or S corporation in a nonrecognition transaction usually will retain its UBIA on the date it was first placed in service by the contributing partner or shareholder. The UBIA of property received in a like-kind exchange is generally the same as the UBIA of the relinquished property. The same rule applies for property acquired as part of an involuntary conversion.
Specified Service Trade or Business (SSTB) limitations
Many of the comments the IRS received after publishing the proposed regs sought further guidance on whether specific types of businesses are SSTBs. The IRS, however, found such analysis beyond the scope of the new guidance. It pointed out that the determination of whether a particular business is an SSTB often depends on its individual facts and circumstances.
Nonetheless, the IRS did establish rules regarding certain kinds of businesses. For example, it states that veterinarians provide health services (which means that they’re subject to the SSTB limits), but real estate and insurance agents and brokers do not provide brokerage services (so they aren’t subject to the limits).
The final regs retain the proposed rule limiting the meaning of the “reputation or skill” clause, also known as the “catch-all.” The clause applies only to cases where an individual or a relevant pass-through entity is engaged in the business of receiving income from endorsements, the licensing of an individual’s likeness or features, or appearance fees.
The IRS also uses the final regs to put a lid on the so-called “crack and pack” strategy, which has been floated as a way to minimize the negative impact of the SSTB limit. The strategy would have allowed entities to split their non-SSTB components into separate entities that charged the SSTBs fees.
The proposed regs generally treat a business that provides more than 80% of its property or services to an SSTB as an SSTB if the businesses share more than 50% common ownership. The final regs eliminate the 80% rule. As a result, when a business provides property or services to an SSTB with 50% or more common ownership, the portion of that business providing property or services to the SSTB will be treated as a separate SSTB.
The final regs also remove the “incidental to an SSTB” rule. The proposed rule requires businesses with at least 50% common ownership and shared expenses with an SSTB to be considered part of the same business for purposes of the deduction if the business’s gross receipts represent 5% or less of the total combined receipts of the business and the SSTB.
Note, though, that businesses with some income that qualifies for the deduction and some that does not can still separate the different activities by keeping separate books to claim the deduction on the eligible income. For example, banking activities (taking deposits, making loans) qualify for the deduction, but wealth management and similar advisory services do not, so a financial services business could separate the bookkeeping for these functions and claim the deduction on the qualifying income.
REIT investments
The TCJA allows individuals a deduction of up to 20% of their combined qualified real estate investment trust (REIT) dividends and qualified publicly traded partnership (PTP) income, including dividends and income earned through pass-through entities. The new guidance clarifies that shareholders of mutual funds with REIT investments can apply the deduction. The IRS is still considering whether PTP investments held via mutual funds qualify.
QBI deduction in action
The QBI deduction generally allows partnerships, limited liability companies, S corporations and sole proprietorships to deduct up to 20% of QBI received. QBI is the net amount of income, gains, deductions and losses (excluding reasonable compensation, certain investment items and payments to partners) for services rendered. The calculation is performed for each qualified business and aggregated. (If the net amount is below zero, it’s treated as a loss for the following year, reducing that year’s QBI deduction.)
If a taxpayer’s taxable income exceeds $157,500 for single filers or $315,000 for joint filers, a wage limit begins phasing in. Under the limit, the deduction can’t exceed the greater of 1) 50% of the business’s W-2 wages or 2) 25% of the W-2 wages plus 2.5% of the unadjusted basis immediately after acquisition (UBIA) of qualified business property (QBP).
For a partnership or S corporation, each partner or shareholder is treated as having paid W-2 wages for the tax year in an amount equal to his or her allocable share of the W-2 wages paid by the entity for the tax year. The UBIA of qualified property generally is the purchase price of tangible depreciable property held at the end of the tax year.
The application of the limit is phased in for individuals with taxable income exceeding the threshold amount, over the next $100,000 of taxable income for married individuals filing jointly or the next $50,000 for single filers. The limit phases in completely when taxable income exceeds $415,000 for joint filers and $207,500 for single filers.
The amount of the deduction generally can’t exceed 20% of the taxable income less any net capital gains. So, for example, let’s say a married couple owns a business. If their QBI with no net capital gains is $400,000 and their taxable income is $300,000, the deduction is limited to 20% of $300,000, or $60,000.
The QBI deduction is further limited for SSTBs. SSTBs include, among others, businesses involving law, financial, health, brokerage and consulting services, as well as any business (other than engineering and architecture) where the principal asset is the reputation or skill of an employee or owner. The QBI deduction for SSTBs begins to phase in at $315,000 in taxable income for married taxpayers filing jointly and $157,500 for single filers, and phasing in completely at $415,000 and $207,500, respectively (the same thresholds at which the wage limit phases in).
The QBI deduction applies to taxable income and doesn’t come into play when computing adjusted gross income (AGI). It’s available to taxpayers who itemize deductions, as well as those who don’t itemize, and to those paying the alternative minimum tax.
Proceed with caution
The tax code imposes a penalty for underpayments of income tax that exceed the greater of 10% of the correct amount of tax or $5,000. But the TCJA leaves less room for error by taxpayers claiming the QBI deduction: It lowers the threshold for the underpayment penalty for such taxpayers to 5%.
Please contact your tax advisor to avoid such penalties and review your specific facts and circumstances regarding the QBI deduction.
Review our QBI Flow Chart using your facts and circumstances to answer the question, “Am I eligible for the new 20% Qualified Business Income (QBI) Deduction?”
The Colorado Department of Revenue issued the following statement regarding proposed sales tax rules to implement the U.S. Supreme Court’s South Dakota v. Wayfair decision and destination sourcing:
“As part of our rulemaking process to implement sales tax rules for in-state and out-of-state retailers, we have heard from legislators and the business community, and the Department of Revenue agrees it is important for the state to take the time to get this right.
“As such, the Department is extending the automatic reprieve for Colorado businesses and out-of-state retailers to comply with the emergency rules from the current March 31, 2019 deadline to May 31, 2019. We will evaluate the need for another extension as May 31 nears. This additional time will give the state legislature an opportunity to find innovative solutions to streamline and simplify our sales tax collection laws in accordance with the wishes of the residents of Colorado.
“This is an opportunity to simplify sales tax for all parties: for businesses that collect and remit sales tax, for customers who pay it, and for those of us in state government whose obligation it is to carry out the tax laws passed by the state legislature. No one desires a streamlined and simplified sales tax collection and compliance system more than the Department of Revenue.”
If you have questions about sales tax in Colorado or in other states, please contact your tax advisor.
A taxpayer’s annual tax liability is based on numerous personal circumstances and life events. For wage-earning taxpayers, federal income tax is paid when income is received via paycheck withholdings. In general, taxpayers are encouraged to update paycheck withholding allowances (Form W-4) to account for significant life changes (e.g., increase in wages, the number of dependents, changes in marital status).
Tax reform created an additional reason to review paycheck withholdings: Confirm how the new laws impact your personal circumstances and preferences.
Tax reform lowered and broadened income tax brackets, doubled the standard deduction and eliminated personal exemptions. The IRS subsequently updated income tax withholding tables, one of the guidelines employers use to determine how much to retain for taxes from employee paychecks. The amount withheld is further customized by an employee’s W-4.
In many cases, employer withholding amounts went down, enabling employees to enjoy slightly higher paychecks; yet many Americans left their W-4s unchanged. Consequently, many W-2 wage earners have found themselves under-withheld for the 2018 tax year. Fortunately, the
IRS waived the penalty for many taxpayers who paid at least 80% of their total tax liability.
The IRS shared that it is “especially important” that certain groups with more “complicated financial situations” should check their withholdings.
These include:
• Two-income families.
• People working two or more jobs or who only work for part of the year.
• People with children who claim credits such as the Child Tax Credit.
• People with older dependents, including children age 17 or older.
• People who itemized deductions in the prior tax year.
• People with high incomes and more complex tax returns.
• People with large tax refunds or large tax bills in the prior years.
It is important to note that receiving a refund or owing taxes does not indicate that your overall annual tax liability has increased or decreased. Your effective tax rate, or the percentage of your annual total income paid in federal income tax, often provides a clearer comparison.
Please consult with your tax professional to learn more about your specific tax rate and identify if adjustments should be made to your withholdings for the current tax year.
Article was updated on 3/22/19 to reflect the IRS expansion of the penalty waiver.
Ten Warnings Signs:
If you have compliance questions on your employee benefit plan, please contact the SKR+CO audit team.