What’s All The Hubbub About Captive Insurance Companies?

Why are we hearing more about Captive Insurance Companies at happy hours, networking deals and professional conferences? Well, it’s simple… people are more open now to new ideas to lessen their tax burden than they were in 2011.

It doesn’t take an Ivy League education to figure out that out of the top 5% of taxable income earners in America – (the vast majority being hard working successful business owners like you) have watched their effective tax rate increase from the low 30’s to an effective rate of almost 40% in the last couple of years. Between our wars in Iraq and Afghanistan, and the “sucking sound” created by promises in the Affordable Care Act – there is no relief in sight from these higher tax rates in the foreseeable future.

Regardless of the reasons or your political persuasion, – John or Jane business owner operating in North Texas, whether in a growing service business, a construction company, a small manufacturer, or a franchisee with 10 dry cleaners, are getting taxed… and taxed hard.

When these business owners become tax “stunned” they become both more creative, more resilient, and more receptive to ideas to help them save on their tax bill. When that occurs certain ideas that were previously reserved for a few (the fortune 500 or fortune 1000 size companies)…. start having traction with middle market companies that may have revenues of 10MM to 200MM, have a strong cash flow, or a fairly predictable earnings history year over year.

So, enough about the why. How do captives work for the common business owner? What does he need to be aware of?  Where is the sizzle in the steak? And finally… What risks do you need to avoid if you are a 5%-er that wants to explore Captives?

 

How They Work

The operating or income producing company (your company) forms a captive and basically pays annual premiums to ensure against risks and pays the premiums to a newly formed insurance company that you own and/or control…

By paying premiums of $500K and you will receive a $500K deduction. Your insurance company receives the $500,000, pays $70k to $100k in operating expenses, small claims settlements and maintenance costs, and assuming no major claims occur- your insurance company makes a profit of around $400K per year.

A specific code section and available election under Sec. 831b, available only to small closely held captives with premiums of less than $1.2 MM annually, keeps the captive from having to pay tax on the premiums it receives at the insurance company level, and it only has to pay tax on its investment earnings.

Meaning, you are getting a deduction for 500K, and your captive is not paying tax on the $400K on the other side.

If your business does this for ten years with no major claims- then your insurance company and its owners has amassed $4,000,000 inside the insurance company which they can dividend or liquidate at 20 to 24% tax rates to the owners of the Captive (you and your family).

If you and your spouse’s net worth exceeds 10MM, you can also, with careful planning, set up your Captive ownership outside of your estate, saving your family an additional 50% of that 4 million in estate taxes that can be passed on to your heirs instead of the IRS.  Over ten years you have likewise saved $2,000,000 in your operating company from ten years of getting $200,000 a year in tax benefit (500,000 x 40%).

In other words, you are getting a 40% deduction and accumulating wealth on a deferred tax advantaged basis over time, which lets you accumulate faster and achieve greater returns.

So friends that’s where the SIZZLE in the steak comes from – the tax rate arbitrage and the estate planning you can accomplish by having your kids own the shares of the captive. Keeping your captive outside of your estate makes for a nifty tax advantaged structure for building wealth transfer to future generations.

 

So, that’s The Good News. What’s the Downsides- or Things to Avoid?

  1. First and foremost – illegitimate or thinly veneered promoters that are selling captives as promoted tax shelters versus an experienced risk management insurance company or Captive management company that operates in the fairway and will advise you correctly on insurable risks and doing it right, with real actuaries that have been doing this a long time.
  2. Insuring faux (not legitimate) or real risks inside your company. For example, anti-terrorism insurance for a small group of doctors versus real risks like malpractice.
  3. Not evaluating your liquidity needs, knowing what is reasonably possible regarding funding of premiums, and how realistic it will be annually to manage your premium levels and payments. While it is possible to change your risks that you cover to toggle or increase or decrease your premiums actuarially, it may reduce the efficacy of your insurance company.
  4. Making sure under your accounting method you can properly deduct the premiums, kind of a bad deal if you go through all this and then remember your cash basis business has to write a 500K check by 12/31 and it doesn’t have the funds to make this happen.
  5. IRS scrutiny- Captives primarily because of the promoters mentioned in #1 above have received a jaundiced eye by our friends at the IRS, and captives even made the dirty dozen list published by the IRS annually for targeted tax scams.
  6. So there are some of our clients that would not be comfortable with this kid of exposure legitimate or not , and then there are some clients that are ok with it because they have done the right things by having the right kind of advisors and captive operators that don’t deal in the fringe element.
  7. Claims- if your captive is legitimate – you will have claims and occasionally some of those could be expensive. How your operating company manages its risks as well as how your Captive manages its reserves and risk can be a difference maker in this area.

 

So If This Is Something You Want To Explore Further, What Are Your Steps?

First, a business owner through his insurance company, financial advisor, or CPA is referred in to a company that can help him form and organize a new Captive Insurance Company and manage its operations going forward.

The CPA works with the captive management company, the business management team, their existing insurance agents or risk manager to come up with a team approach to risk management and evaluate the overall feasibility of using a Captive as a part of the overall risk management plan of the business.

A captive insurance company is a fully licensed insurance company owned by the business or the business owners. It is a unique entity and is a standalone insurance company with policies, policy holders, risks, claims, and a license to do business in various domiciles – some domestic and some off shore.

What does this cost – well of course it varies – but the set up seems to run somewhere between $50K and $70K – with some variability to this figure if you use a domestic captive (with higher initial capital formation requirement), or a foreign captive that may have less stringent initial capitalization requirements.

Done well, a CIC strategy can be a great tool for tax-advantaged risk management and wealth preservation- the veritable combo pack that most of us are looking for. To learn more about it contact Gary Jackson or Cornwell Jackson’s strategic alliances and advisors in this area.

Blog post written by: Gary Jackson, Tax and Advisory Partner

My CPA Conference at Disneyworld

disneyLast month, I packed the family up and we jetted to Orlando for a fully deductible summer family vacation.  Now, of course, it was technically a fully deductible continuing education conference as far as IRS rules go.  It was the perfect setting for my 8 and 11-year-old kids.  The plan was for my wife and mother-in-law to go to all the Disney parks while I was in class learning about new accounting rules and trends in the accounting industry.  In fact, that is exactly what happened, and luckily I was able to stay over a couple of extra days to be with them at the Disneyworld parks.

I found the classes very interesting as a significant portion of the content covered the powerful impact of technology changes that are having a dramatic impact to our firm and our clients by increasing efficiencies that increase the bottom line.  The opportunity for our clients is to reduce their back office overhead cost by outsourcing these processes.  I left the conference motivated by the fact that our firm can truly help our clients more than ever before and that we are becoming the accounting and business services firm of the future.

Before heading home, it was off to Disneyworld to take on all the fun Orlando has to offer.  We arrived at the park as it opened for the day.  It was already hot and humid in the morning. So, I was not sure how much fun it would be.  We hit the ground running and made the most of our day despite the heat.  By halfway through the day I began to become increasingly impressed with the park operations.  Everything we experienced was very intentional, meaning there was going to be NO accidental fun.  Every detail of our experience we extremely well thought-out from the beginning until the end of every ride, theme, and experience.  I realized Disney was one of the most efficient engines I had ever seen in a business operation.  I may have learned some great things at the conference, but it was not until I took in Disney that I got the most eye-opening lesson on intentional profitable operations.

Its culture is built around the term ‘plus it’ which was used by Walt Disney to continuously further improve projects whether it be a film, TV show, or park.  I kept thinking to myself, what if our firm and our clients could actually create such an efficient economic engine and how awesome it would be to witness the results on a daily basis.  As business owners, we strive to reap the rewards of our hard work.  For example, we tend to buy the most highly engineered vehicles on the market.  But when it comes to our business operations we cut corners on engineering of our operations and then use prayer and hope that our employees will get-‘er-done using some sort of R&I (resourcefulness and intuition) to provide our services to our customers.

From the time you step off the plane in Orlando, you enter the kingdom so to speak.  You will notice how clean the airport and shuttles are at the influence of Disney.  You can begin your experience with the Disney Magic Band to express check-in, and unlock your hotel room as you arrive without having to wait in line for check-in.  The Magic Band allows you to charge and purchase food and items and connects you to the Disney photo pass and fast pass.  You fast pass to the front of the line and when your attraction ride is over you just wave it on over a reader for your picture that was taken during the attraction ride and it can be purchased anytime later so you don’t have to spend time cutting into your family fun.

I can only image the planning and strategy that goes into the delivery of an attraction on a Disney property.  Each attraction is developed to have a purpose and their customers are entertained from the end of the line all the way through the end of the ride.  The characters are controlled through an extensive network of digital animation that provides a consistent repeatable experience for its customers.  As you walk from one attraction to another it is apparent that the park is very clean and there is plenty of space to walk around.  It utilizes a system of utilidors that allows personnel, retail goods, and supplies to be moved through underground tunnels.  There is another underground system that uses compressed air to collect and transfer trash off the property.

Being an accountant, I thought I would put their financial statements to the test.  I downloaded their last Annual Report filed with the SEC to get to their bottom line.  Is all this worth it I was wondering.  Well, Disney’s year over year growth ‘and’ net profit was in the billions.  Their profit was 15% of gross revenue.  Now that is a well-oiled machine!

So my conference was a success in a way that I did not expect.  I arrived to learn from all the experts in our industry.  There were numerous vendors, subject matter experts, and consultants that wanted to share their knowledge with all the CPA’s and accountants from across the country.  They covered areas of technical rule changes, operations, marketing, and management.  Outside of the technical rule changes, there existed a collaborative effort through over 100 courses with varying topics to cover and talk about concepts that can have a positive impact on efficiencies for our clients.  Better said there was a tremendous amount of talking.  But in the end I witnessed actual efficiencies live in action at Disneyworld that turned into the best lesson I got at the conference.

As a business owner can you imagine having a highly engineered engine running your business?  What if you had a process that ran itself and provided you information in real time to make course corrections?  You take your stress home from work.  Work can be more stressful if it relies heavily on employees who do it the best way they can which is their way and not THE way.  THE way is your strategic way that allows you to work less and make much more money.  Then you can enjoy the financial freedom on your terms and be a happier leader at home and at work.

Now not everyone can throw off a billion dollar bottom line but why not try to get the most out of your business.  Take the first step and create a Disney culture of ‘plus-it’ to move the needle on your business.  The first step is to begin automating your processes. You also need to develop processes to make your business smarter and more efficient to reduce costs and increase productivity. Here are some examples:

  • Eliminate cumbersome and time consuming manual tasks such as: data entry, envelope stuffing, filing and check runs
  • Pay bills online at a fraction of the time it takes to process and sign checks
  • Automate customer collections
  • Stop opening mail by having the vendor emails sent directly into the accounting software
  • Reduce human error and increase accuracy with automated software
  • Improve internal controls to reduce the risk of fraud
  • Improve timely reporting of financial results
  • Improve collaboration of your limited resources

Let ‘your’ team use their business experience which is not as much dependent on technology to help your employees and customers which will ultimately help you grow the company and have the peace of mind that your company is operating in a smarter and more profitable way. Go and Grow can help you put the processes in place and become your back office at a much lower cost with better controls.

Small Business Reprieve on Health Premium Reimbursement Plans

Historically, companies that wanted their employees to be protected with health coverage, but didn’t want the hassle of having a company health plan, could simply give employees an amount of money sufficient to reimburse them for the cost of buying the coverage (or some portion of it). As long as the individuals provided evidence that they used those funds for health coverage, the dollars were excludable from taxable income for the employees.

Alternatively, companies could just pay the premiums directly to the insurance carrier.

However, back in November 2014, the Department of Labor (DOL) declared that companies reimbursing employees for medical care instead of offering a health care plan is the equivalent of having a health plan and is subject to the Affordable Care Act (ACA). And since those reimbursement arrangements failed to meet ACA requirements in two ways — that is, the condition that group health plans have no annual limits on benefits, and that no co-pay for certain preventive health services must be paid — they were ruled to be noncompliant with the law.

Per Employee Penalty

This DOL ruling reiterated 2013 guidance from the IRS. The kicker: Beginning in 2014, companies with such reimbursement arrangements in place would be subject to a $36,500 penalty per employee.

The only remedy offered by the DOL was for companies to gross up those contributions (that is, add to them enough money to cover the tax liability employees would incur as a result of receiving the payments), plus make it clear to employees that they could do whatever they wanted with all of the money they received. In other words, they would not be required to use it to pay for health coverage.

The IRS’s latest ruling, Notice 2015-17, which the tax agency says is in sync with the most recent DOL policy on the matter, gives everyone time to catch their breath.

Specifically, small businesses with reimbursement plans in place will not be penalized unless they maintain them beyond June 30 of this year. Small businesses are also off the hook for having to file Form 8928, which is the form that covers failures to satisfy group health plan requirements. Originally, that form would have been required with companies’ 2014 tax returns.

The reprieve also applies to plans that help retirees pick up the tab for Medicare Part B and D premiums.

Employees with S Corp Stock

Employees who own at least 2 percent of their employers’ stock (if the company is an S corp) are treated differently. Such employees were required to report the premium reimbursement payments as income on their 1040s, even though the payments were not subject to payroll tax. But those same employees could also take a deduction equal to the amount of that income, leaving them tax neutral.

In IRS Notice 2015-17, the tax agency warns that it and the DOL “are contemplating publication of additional guidance on the application of the market reforms to a 2 percent shareholder-employee healthcare arrangement.” Until then, however, the companies are off the hook. So, too, are the employees who will continue to be allowed to deduct that income as self-employed health insurance premiums.

Notice 2015-17 reconciles the IRS with a position the DOL had taken earlier — that is, declaring reimbursement plans as merely taxable payments to employees doesn’t prevent them from being deemed health plans. That means the only way to help employees secure health coverage without having a bona fide health plan is to just give each employee a raise and hope they will use it to buy their own health coverage. (Keep in mind, small businesses with fewer than 50 employees and full-time equivalents are not required to provide health plans under the ACA.)

The guidance also made it clear that the ACA’s market reforms, as they pertain to this issue, don’t extend to arrangements covering only a single employee (regardless of whether that employee is a 2 percent-or-more shareholder). That means if you own your company and aren’t an employee, but you have one employee and want to reimburse that person for the cost of buying individual coverage, you won’t be subject to any penalties.

Monthly Health Allowances

Meanwhile, the entrepreneurial spirit of America is at work to help small businesses that just want to help employees pay for individual coverage, but don’t want to run afoul of the IRS and DOL. One benefits company offers a web-based defined contribution arrangement it calls “Individual Health Reimbursement for Small Business.” It gives employees access to a “monthly health allowance.” However, companies considering such arrangements should consult legal counsel for an opinion as to whether the plan would pass muster with the IRS and DOL.

S Corps and Partnerships: Beware of Failure-to-File Penalties

fAILURE TO FILE PENALTY

The S corporation is a popular business structure that’s available only to privately held businesses. In fact, approximately 44 percent of small employer firms — generally defined as companies with fewer than 500 employees — have elected to operate as S corporations, according to the U.S. Small Business Administration’s Office of Advocacy. (By comparison, only 22 percent of small employer firms operate as C corporations.)

The primary reasons for electing S status are:

  1. To retain the limited liability of a corporation; and
  2. To pass corporate income, losses, deductions, and credit through to shareholders for federal tax purposes.

In other words, S corporations generally avoid double taxation of corporate income. Instead, S corporation shareholders report the pass-through of these tax items on their personal tax returns and pay tax at their individual income tax rates.

However, if you operate a business as an S corporation, there’s a relatively steep penalty for failure to file a timely federal return each year using Form 1120S. One recent U.S. Tax Court decision illustrates the point. A parallel failure-to-file penalty applies to partnership returns that aren’t filed on time using Form 1065.

S Corp Failure-to-File Penalty

The penalty for failure to file a federal S corporation tax return on Form 1120S — or failure to provide complete information on the return — is $195 per shareholder per month. The penalty can be assessed for a maximum of 12 months.

For example, the monthly penalty for failing to file a calendar-year 2014 Form 1120S for an S corporation with three shareholders is $585 ($195 times three). If the return remains unfiled for 12 months or more, the maximum penalty equals the monthly penalty multiplied by 12. So the maximum failure-to-file penalty for a three-owner S corporation would be $7,020 ($585 times 12).

Important Note: Many federal tax penalties are assessed based on the amount of tax owed. So these penalties cannot be assessed if the taxpayer doesn’t have positive taxable income and a resulting tax bill. However, the S corporation failure-to-file penalty can be assessed whether the S corporation produces positive taxable income or not. Therefore, filing S corporation returns can’t be ignored because no tax is owed.

Facts of the Recent Case

Babak Roshdieh was the sole shareholder of a California medical services S corporation, which was the taxpayer in this case. The corporation had a history of filing its federal income tax returns late. This case specifically involves the 2010 return, which was due on March 15, 2011. The corporate secretary claimed that he sent in a request for an extension to file the return by regular first-class mail. The IRS claimed the extension request was never received.

According to a certified transcript, the Form 1120S for 2010 was received by the IRS via regular first-class mail on January 31, 2012. The IRS then assessed a $2,145 failure-to-file penalty based on the return being filed 11 months late ($195 times 11 equals $2,145).

The IRS offered to settle for less than the full amount of the penalty assessment, but the offer was refused. Eventually, the case wound up in U.S. Tax Court. At trial, the taxpayer claimed that a timely request for a six-month filing extension to September 15, 2011, had been filed for the 2010 federal tax return, and that the 2010 return had been filed on October 15, 2011 (one month late). Therefore, the taxpayer claimed that only $195 was owed for the failure-to-file penalty. The IRS position was that no extension request was received, and the 2010 return wasn’t received until January 31, 2012.

The taxpayer’s corporate secretary also claimed that he had filed extension requests for every corporate tax year from 2002 through 2013. But the secretary offered no evidence to support his claim. The IRS provided certified transcripts showing that it had received extension requests for only six of the 12 years. Finally, the taxpayer was unable to offer proof that the 2010 return was filed on October 15, 2011, as claimed.

Tax Court Decision

Based on the available information, the Tax Court concluded that no request to extend the corporation’s 2010 return had been received by the IRS, and that the 2010 return wasn’t received by the IRS until January 31, 2012. Therefore, the full penalty assessment was upheld. (Babak Roshdieh M.D. Corp., T.C. Summary Opinion 2014-113)

Same Thing Can Happen with Late-Filed Partnership Returns

Subject to limited exceptions, unincorporated businesses and investment ventures with two or more participants are treated as partnerships for federal income tax purposes. It doesn’t matter if the venture isn’t formally organized as a partnership under applicable state law. Ventures that are treated as partnerships for federal tax purposes must file annual federal returns using Form 1065. The potential penalty for failure to file a partnership return — or failure to provide complete information on the return — is also $195 per partner per month. The penalty can be assessed for a maximum of 12 months.

Therefore, the same failure-to-file penalty issue can potentially arise with partnerships. But the risk may be even higher in this scenario because business venture participants sometimes don’t realize they have created a partnership for tax purposes, and that federal returns are due.

Bottom Line

S corporations and other business ventures with two or more participants, which are treated as partnerships for tax purposes, must file timely annual federal returns or potentially face steep failure-to-file penalties. These penalties can be assessed even though the S corporation or partnership in question doesn’t produce positive taxable income. Whenever you become involved in a business or investment activity, consult with your tax adviser regarding necessary tax filings and professional tax preparation.

Contemplating a Switch?

Many private businesses elect to operate as S corporations, but not every business is eligible.

In order to make the switch, your business must meet certain requirements, including:

  • Be a domestic corporation;
  • Have no more than 100 shareholders;
  • Have only one class of stock; and
  • Not be an ineligible corporation, including certain financial institutions, insurance companies, and domestic international sales corporations.

All shareholders must consent to the S corporation election by signing an IRS form.

Another important consideration when electing S status is shareholder compensation. The IRS closely monitors how much S corporations pay shareholders who work for the company. Agents are on the lookout for S corporations that underpay shareholders to avoid paying employment taxes. A combination of low salaries and high distributions could become a red flag that elicits unwanted attention from the IRS.

To the extent that a shareholder’s compensation doesn’t reflect the fair market value of the services he or she provides, the IRS may reclassify a portion of earnings as unpaid wages and additional employment tax on the reclassified wages will be owed.

Consider all the pros and cons and consult with your tax and legal advisers before making the switch from C to S corporation status.

Ten Tax Breaks Available for Parents

How much money do you need to raise a child? According to an estimate from the U.S. Department of Agriculture, it will cost a middle-income couple roughly $245,000 to raise a child born in 2013 to the age of 18. This is up 1.8 percent from the prior year. Plus, the estimated average cost is much higher in certain parts of the country. For example, high-income families living in the urban Northeast United States are projected to spend almost $455,000 to raise a child for 18 years.

These figures cover costs for housing, food, transportation, clothing, health care, education, childcare, and miscellaneous expenses such as cell phones and sports team fees. But they do not include college. That can easily add tens or hundreds of thousands of extra dollars to the tab.

Here is a list of 10 Federal Tax Breaks for Parents.

  1. Dependency Exemptions

You can generally claim a dependency exemption for a child under age 19 or a full-time student under age 24, if you provide more than half of the child’s annual support. Each dependency exemption is $4,000 for 2015. However, you may lose at least part of the benefit of your exemptions if your adjusted gross income (AGI) is above a certain amount.

  1. Child Tax Credit

Parents may be entitled to the child tax credit for each qualifying child under age 17 at the end of the year. The maximum credit for 2015 is $1,000 per child.

You may lose at least part of the benefit of your exemptions if your modified adjusted gross income (MAGI) is above a certain amount. To qualify, you must meet certain criteria regarding the child.

  1. Child and Dependent Care Credit

Another tax credit may be claimed if you pay someone to care for a child under the age of 13, allowing you (and your spouse, if married) to be gainfully employed. The child and dependent care credit is based on a sliding scale. For parents with an AGI of more than $43,000, it’s equal to 20 percent of qualified expenses paid to a qualified caregiver to ensure the child’s well-being and protection. The total expenses that you may use to calculate the credit should not be more than $3,000 for one qualifying child or $6,000 for two or more qualifying children.

  1. Earned Income Tax Credit (EITC)

This credit is only available to certain lower-income families. On a 2015 return, the maximum EITC amount available is $3,359 for taxpayers filing jointly with one child; $5,548 for two children; and $6,242 for three or more children. You may be eligible for the EITC without a qualifying child, but the credit is higher for families with children. If you can claim the EITC on your federal income tax return, you may be able to take a similar credit on your state or local income tax return, where available.

  1. Adoption Credit

If you adopt a child, you may be eligible for a special tax credit for qualifying expenses. On a 2015 return, the maximum adoption credit is equal to $13,400 of the qualified expenses incurred to adopt an eligible child. However, credit amounts are phased out for upper-income taxpayers based on MAGI. The adoption credit begins to phase out for taxpayers with MAGI of $201,010 and is eliminated for those with MAGI of $241,010 or more.

  1. Higher Education Credits

If you pay higher education costs for yourself or an immediate family member, including a child, you may qualify for one of two education tax credits (but you can’t claim both). The maximum American Opportunity Tax Credit is $2,500 per student while the maximum Lifetime Learning Credit is $2,000 per taxpayer. Both higher education credits are phased out for upper-income taxpayers based on MAGI.

  1. Tuition Deduction

The deduction for qualified tuition and fee expenses, which had expired after 2013, was retroactively extended for 2014 by new legislation. It’s on the list of tax breaks Congress will address extending in 2015. Depending on your MAGI, the deduction on a 2014 return is either $4,000 or $2,000 before it’s completely phased out. Note that you can’t deduct tuition expenses if you claim one of the higher education credits.

  1. Student Loan Interest

You may be able to deduct interest you paid on a qualified student loan up to a maximum of $2,500 for 2015. This “above the line” deduction can be claimed whether or not you itemize deductions on your tax return. You can only claim the deduction if your MAGI is less than a specified amount, which is set annually. The amount of student loan interest is phased out if your MAGI is between $65,000 and $80,000 ($130,000 and $160,000 if you are married and file jointly).

  1. Self-Employed Health Insurance Deduction

If you’re self-employed and pay for health insurance, you may be able to deduct premiums paid to cover your child, as well as yourself and your spouse, if married. This tax break, which was authorized by the Affordable Care Act, applies to children who are under age 27 at the end of the year, even if the child isn’t your dependent.

  1. Potential Lower Tax Rates

Last but not least, parents may be able to benefit from shifting income-generating assets to children. As a result, income that is normally taxed to the parents in their high tax bracket is taxed to the children in their lower tax brackets. Of course, this means you must give up control over the assets.

However, remember that this strategy may be mitigated by the Kiddie Tax. Under the “Kiddie Tax,” the unearned income received by a dependent child under age 19, or a full-time student under age 24, is taxed at the top rate of the child’s parents to the extent that it exceeds $2,100 in 2015.

For more information about any of the above 10 child tax breaks — including limitations, detailed rules, and exceptions — contact our tax advisor.

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