Tax Cuts and Jobs Act Planning Letter for Business Clients

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Newsletter from
Steve Richardson & Company, Certified Public Accountants

June 27, 2018

Tax Cuts and Jobs Act Planning Letter for Business Clients

To Our Clients and Friends:

Over the past six months, we have been trying to digest the many tax law changes brought by the Tax Cuts and Jobs Act (TCJA). From a significantly lower corporate tax rate to a new deduction for qualified business income, the TCJA brings a host of planning opportunities for your business. This letter presents some tax planning ideas under the TCJA for you to think about this summer while there’s sufficient time left in 2018 to take tax-saving actions.

The Obvious Requirement to have any Tax Planning Strategy

Unless you are making profit in business, or have excellent prospect to make a business profit in the future, there is no Tax Planning Strategy appropriate for you!  Losing money is not tax planning!  Making a profit opens many doors; one of these doors is the ability to develop a tax planning strategy.

Maximize Your Qualified Business Income Deduction

You may have heard a lot of talk in the news about a new deduction for “pass-through” income, but it’s actually available for qualified business income from a sole proprietorship (including a farm), as well as from pass-through entities such as partnerships, LLCs, and S corporations. Under the TCJA, business owners may deduct up to 20% of their qualified business income; however, the deduction is subject to various rules and limitations.

Although official guidance is lacking on this new deduction, there are some planning strategies that can be considered now. For example, there are ways to adjust your business’s W-2 wages to maximize your qualified business income deduction. Also, it may be helpful to convert your independent contractors to employees, assuming the benefit of the deduction outweighs the increased payroll tax burden. Other planning strategies include investing in short-lived depreciable assets, restructuring the business, and leasing or selling property between businesses. We will work with you to determine which strategies produce the best outcome.

Rethink Entity Choice

The TCJA makes major changes to the choice of entity decision. Because C corporations are now taxed at a flat rate of 21% (as opposed to a top rate of 35% under prior law), many business owners wonder whether they should structure or restructure their business operations as a C corporation.

Generally speaking, for most small businesses, I recommend against C corporations.

For one thing, the top individual tax rate also fell, from 39.6% to 37%. Also, the new qualified business income deduction isn’t available for C corporations or their shareholders. There are other factors to consider as well, such as self-employment and state taxes.

It’s also important to note that C corporations are subject to double taxation, meaning that corporate income is taxed once at the entity level and again when it’s distributed to shareholders as dividends. This can be avoided if the corporation retains all profits to finance growth. However, this opens the door to the accumulated earnings tax (or personal holding company tax) if profits accumulate beyond the reasonable needs of the business.

Although C corporations are now more attractive thanks to the lower rate, it may make more sense to continue operating as a pass-through entity. This is particularly true if (1) you can claim the full 20% deduction for qualified business income and (2) you plan to exit the business in a relatively short period of time. Generally, it’s risky to hold significant assets that are likely to go up in value (like real estate) in a C corporation. If the assets are sold for substantial gains, it may be impossible to get the profits out of the corporation without double taxation.

As you can see, the choice of entity decision is complicated, but we’re here to help. We would be happy to analyze your particular circumstances to see if a C corporation is right for you.

Acquire Assets

Thanks to the TCJA, this is a great time to acquire business assets. Your business may be able to take advantage of very generous Section 179 deduction rules. Under these rules, businesses can elect to write off the entire cost of qualifying property rather than recovering it through depreciation. The maximum amount that can be expensed this year is $1 million (up from $510,000 for 2017). This amount is reduced (but not below zero) by the amount by which the cost of qualifying property exceeds $2.5 million (up from $2.03 million for 2017).

There’s more good news: the Section 179 deduction is now available for certain tangible personal property used predominantly to furnish lodging and certain improvements to nonresidential real property (roofs, HVAC, fire protection systems, alarm systems, and security systems).  This is new!

Note: Watch out if your business is already expected to have a tax loss for the year (or close) before considering any Section 179 deduction. This is because:

You can’t claim a Section 179 write-off that would create or increase an overall business tax loss.

Above and beyond the Section 179 deduction, your business also can claim first-year bonus depreciation. The TCJA establishes a 100% first-year deduction for qualified property acquired and placed in service after 9/27/17 and before 1/1/23 (1/1/24 for certain property with longer production periods).

Unlike under prior law, this provision applies to new and used property.

The bonus percentage will phase down for years 2023 through 2026. Note that 100% bonus depreciation deductions can create or increase a Net Operating Loss (NOL) for your business’s 2018 tax year.

NOLs

NOL is a common tax acronym that means a Net Operating Loss. Under the TCJA, the NOL generally can’t be carried back to an earlier tax year. However, it can be carried forward indefinitely. Unfortunately, NOLs arising in tax years beginning after 2017 can’t reduce taxable income by more than 80%.

Given these generous provisions, your asset acquisition plan is more important than ever. If you’re planning on acquiring a business, we suggest you pursue an asset acquisition rather than a stock deal. Also, there may be reasons to elect out of bonus deprecation or use different expensing techniques in individual tax years. We can help with that.

Adopt a More Favorable Accounting Method

The cash method of accounting, which allows you to recognize sales when cash is received, is attractive to many small businesses due to its simplicity. For tax years beginning after 2017, the ability to use the cash method is greatly expanded. Any entity (other than a tax shelter) with three-year average annual gross receipts of $25 million or less can use the cash method regardless of whether the purchase, production, or sale of merchandise is an income-producing factor. Likewise, C corporations and partnerships with C corporation partners can use the cash method if they meet the $25 million gross receipts test.

Under pre-TCJA law, the cash method of tax accounting was not allowed to many taxpayers.  That has changed dramatically!

Now that the rules have changed, your business may be eligible to adopt the cash method of accounting. Since the $25 million gross receipts test is made on a year-by-year basis, we can monitor whether your average annual gross receipts fall below the threshold. If they do, we can discuss the pros and cons of changing your accounting method. Assuming a change would be beneficial, we can file the appropriate paperwork with the IRS to change your method of accounting.

Personally, as a CPA, I like the cash method of accounting.

Determine Eligibility for Credit for Employer-paid Family and Medical Leave

The TCJA establishes a new credit for employer-paid family and medical leave. The credit is for tax years beginning in 2018 and 2019 and is equal to 12.5% of the amount of wages paid to qualifying employees on family and medical leave. However, the employer must pay at least 50% of the wages normally paid to the employee. The credit is increased by 0.25 percentage points (but not above 25%) for each percent by which the payment rate exceeds 50%. This could be a valuable incentive for your business, so let’s discuss at your earliest convenience.

Watch out for New Business Interest Expense Limit

Regardless of its form, every business will be subject to a net interest expense disallowance. Starting in 2018, net interest expense in excess of 30% of your business’s adjusted taxable income will be disallowed. However, your business won’t be subject to this rule if its average annual gross receipts for the prior three years is $25 million or less. Also, real property trades or businesses can choose to have the rule not apply if they elect the Alternative Depreciation System (ADS) for real property used in their trade or business. Since ADS is a slower way to depreciate property, real property trades or businesses will need to look at the trade-off between currently deducting their business interest expense and deferring depreciation expense. If you find yourself in this predicament, we can model out both scenarios to determine the best course of action.

Consider Qualified Equity Grants

The TCJA provides a new tax election for equity-based compensation from private employers. Specifically, the election covers stock received in connection with the exercise of an option or in settlement of a Restricted Stock Unit (RSU). From a tax perspective, many employees struggle with these forms of compensation because they don’t have the ability to liquidate their shares to pay their tax bill. This new election provides some relief.

Starting with options exercised or RSUs settled after 2017, qualified employees of eligible private companies may elect to defer income from those instruments for up to five years. To take advantage of this election, various requirements must be met. This includes having a written plan under which at least 80% of full-time employees are granted stock options or RSUs.

If you’re interested in offering qualified equity grants to your employees, we can determine if you’re an eligible corporation under this new provision. We can also assist you and your legal counsel in preparing the necessary documentation. Please contact us if you have questions or want more information.

I’m still exploring how qualified equity grants may impact professional organizations such as attorneys, physicians, engineers, architects and others.

Monitor State Response to Tax Reform

Our CPA Firm has active clients in 35 states; state tax issues are a daily reality in our office!

States react differently to changes to federal tax law. For example, some states automatically conform to federal tax law as soon as legislation is passed. Other states require their legislatures to adopt federal tax law as of a fixed date. This generally occurs on an annual basis. There are some states, however, that pick and choose which federal provisions to adopt. Because of this, your state income tax rules may be drastically different than the federal income tax rules. For example, some states may not adopt the new 100% bonus depreciation rules or the NOL rules. We have monitored your state’s response to the TCJA and will help you minimize your state income tax bill.

Set up a Qualified Small Business Corporation

As we mentioned earlier, the TCJA establishes a flat 21% federal income tax rate for C corporations, including Qualified Small Business Corporations (QSBCs). A QSBC is generally a domestic C corporation whose assets don’t exceed $50 million. In addition, 80% or more of the corporation’s assets must be used in the active conduct of a qualified business. There are other requirements as well, but we can fill in the details if you decide a QSBC is right for you.

By far, the biggest benefit of owning QSBC stock is the ability to shelter 100% of the gain from a stock sale. A more-than-five-year holding period requirement must be met to claim this exclusion. Another major benefit of owning QSBC stock is the ability to roll over (defer) the gain on a stock sale to the extent you acquire replacement QSBC stock within 60 days of the original sale. You must have held the QSBC stock for more than six months to take advantage of this break. Once the gain is rolled over, you must reduce the tax basis of the replacement stock by the amount of gain deferred. However, if the replacement stock is QSBC stock when it’s sold, the applicable gain exclusion break is available if the more-than-five-year holding period requirement is met.

The 100% gain exclusion and rollover breaks combined with the flat 21% corporate tax rate can make operating a newly formed business as a QSBC more tax-efficient than operating it as a pass-through entity (sole proprietorship, partnership, LLC, or S corporation). That is big news because pass-through entities have traditionally been the first choice for most small and medium-sized businesses. However, not all start-up businesses will qualify for QSBC status.

A Qualified Small Business Corporations (QSBCs) is not out of the questions for some small businesses.  Essentially, a corporation can elect to become a QSBC if it is in a business other than one involving personal services; banking, insurance, financing, leasing, or investing; farming; mining; or operating a hotel, motel, or restaurant. Essentially, then, permissible businesses include manufacturing, retailing, technology, and wholesaling.  There are circumstances among our clients where a QSBC election may make sense.

Conclusion

As we said at the beginning, this letter is to get you thinking about tax planning moves for the rest of the year. This year is definitely unique given the numerous tax law changes brought by the TCJA. Even with uncertainty about some of the TCJA’s provisions, there are things you can do to improve your business’s situation. Please don’t hesitate to contact us if you want more details or would like to schedule a tax planning session.

I love my job! Thanks to all of my clients and friends who have allowed me to make a good living by doing what I love to do!

Thanks You!

Steve Richardson, CPA

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Asset Protection

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Asset Protection

Introduction

Asset Protection is an important part of any financial or tax planning discussion.

A Crisis Averted

A new client came to our CPA Firm last week after settling a frightening lawsuit. The possibility that they could have lost several million dollars in assets was very real; it was close!

Increasingly people and “for profit” and “not-for-profit” businesses face the routine threat of litigation.  The “Assets Protection” concepts discussed in this newsletter apply equally to commercial businesses just as well as it does to “not-for-profit” businesses.

What follows is, in large part, extracted from the “Asset Protection” letter that I drafted to help my new client avoid the future possibility of losing substantial assets due to litigation.

Social Welfare Services, Inc.

The name that I have arbitrarily assigned to this entity for confidentiality reasons is: Social Welfare Services, Inc.

A Consulting engagement

Not-for-profit organizations, such as Social Welfare Services, Inc., face complex and often dangerous tax situations and legal situations. Our CPA firm has (and has had) many hundreds of §501(c)(3) clients over the years; we have clients who are not-for-profit organizations in 35 states and 25 foreign countries. We have seen non-profits accomplish remarkable and positive things; on rare occasions, these accomplishments had powerful, worldwide impact. We have also seen the opposite; situations so bad that they are beyond belief or comprehension.

Catastrophe

The first rule of managing a catastrophe is this: avoid it!

A “Tax Opinion” Letter

This is a “tax opinion” letter. This letter is subject to strict ethical and legal standards governed by my Code of Conduct, IRS Circular 230 and the Internal Revenue Code.

IRS Circular 230, Section 10.37, sets the required standard to which I must comply when providing a tax opinion in any written communications.

A summary of the rules to which I must comply are:

  • Base the written advice on reasonable factual and legal assumptions, including assumptions as to future events;
  • Reasonably consider all relevant facts the practitioner knows or reasonably should know;
  • Use reasonable efforts to identify and ascertain the facts relevant to written advice on each federal tax matter;
  • Not rely on representations, statements, findings, or agreements (including projections, financial forecasts, or appraisals) of the taxpayer or any other person if reliance on them would be unreasonable;
  • Relate applicable law and authorities to facts; and
  • In evaluating a federal tax matter, not take into account the possibility that a tax return will not be audited or that a matter will not be raised on audit.

I am required to include in the opinion a recitation of the relevant facts, apply the law to those facts, and state the conclusions from applying the law to the facts. The sanctions for a CPA who fail to meet these well understood ethical and legal obligations are harsh.

My Team

I will outline a tax plan that has positive tax and legal consequences. I’m not a lawyer; I rely heavily on outside legal counsel in designing and implementing this sort of plan.

The legal work that will be required to implement this plan will need to be done by competent legal counsel. Some of the law that I will discuss is relatively new. Inexperienced or uninformed attorneys (or accountants) could make mistakes of profound implications.

The “New” Law (2006)

In late 2006 (December 8, 2006), the IRS established a new concept in tax law called a “disregarded entity”. Early on, Alabama allowed for what was at the time a unique corporation called a “Single Member LLC”. Since then, all states now allow this special type of entity.

A “Single Member LLC”, which I will hereinafter refer to as a SMLLC, is a deceptively simple organization with hidden super powers. Two of these “super powers” are that a SMLLC can “disappear” for all purposes of federal income tax law and it can offer strong liability protections under Alabama law.

But, there are other super powers in addition to these two.

Confidence

Early in 2007, prior to clarifying IRS Regulations, I started to explore the use of SMLLCs in connection with §501(c)(3) and other entities to good effect.

Each time I employed a SMLLC ahead of IRS Regulations, the IRS and the Regs ultimately endorsed my actions. I think my forays into this, at the time, obscure branch of tax planning, encouraged my own attorney to be a bit more aggressive in his study of and use of SMLLCs in tax and legal planning.

Thus far, our plans have been effective in accomplishing the intended purposes.

The “Single Member LLC”

The SMLLC is a unique tax entity. A SMLLC has, as you might expect, a single member. That single member could be any legally existing tax entity. For example, a SMLLC could be owned by:

  • An Individual
  • A partnership
  • A corporation
  • A trust, or, as will be the case in this tax plan, or,
  • A §501(c)(3) entity.

A SMLLC has the same limited liability as a Corporation

A SMLLC offers the same limited liability to its owners as corporations for all purposes of state law. Alabama has good, well crafted, laws that support LLCs in general and SMLLC in our particular case.

In fact, LLCs and SMLLCs have, in my opinion, better limited liabilities than a regular (old fashioned) corporation because the old fashioned corporations could have the limited liability shield broken by a long list of accidental or inadvertent oversights such as a failure to have required annual meetings, etc. These meetings are not required for LLCs.

A SMLLC is a Disregarded Entity

Although the SMLLC has some of the more desirable corporate characteristics under Alabama law, it is, for all purposes of federal income tax law, a “disregarded entity”.

As a “disregarded entity” for federal income tax law, a SMLLC then becomes the “same” taxpayer as the owner. If, for example, a SMLLC is owned by a §501(c)(3), then, as far as the IRS is concerned, the SMLLC is a §501(c)(3).

There is no need to seek an IRS determination letter; if the SMLLC is owned by a §501(c)(3), then the SMLLC is automatically a §501(c)(3). (There is a bit more to this in terms of organization and operations in a manner consistent with the exempt purposes of the §501(c)(3), but, not much.)

The Plan

Recent Alabama law related to LLCs and SMLLC has been substantially improved to allow for creative restricting of all business entities including §501(c)(3) organizations.

What I recommend is as follows: Social Welfare Services, Inc. should form the following entities.

  1. Operations and Management, SMLLC
  2. Real Estate, SMLLC
  3. Equipment, SMLLC
  4. Thrift Store #1, SMLLC
  5. RBC Thrift Store #2, SMLLC
  6. Development Funds and Endowment, SMLLC

This structure is seven entities:

  • The parent entity, Social Welfare Services, Inc., an approved §501(c)(3), and:
    • Operations and Management, SMLLC
    • Real Estate, SMLLC
    • Equipment, SMLLC
    • Thrift Store #1, SMLLC
    • RBC Thrift Store #2, SMLLC
    • Development Funds and Endowment, SMLLC

I have tried to apply hypothetical names to these various entities to make the purpose and function obvious; when selecting actual names, I suggest you try to accomplish the same goal.

Operations and Management, SMLLC

This first SMLLC from our list above, Operations and Management, SMLLC, will be the entity that provides facilities, personnel and financial management.

Operations and Management SMLLC is an entity with no tangible assets. Its function is to manage the operations of Social Welfare Services, Inc. in a manner consistent with the organization’s exempt purposes. It will be responsible for all bookkeeping, accounting, personnel and payroll activities for all the entities.

Operations and Management SMLLC should keep minimal cash in the bank balances for operational purposes only. Savings accounts and other cash assets need to be move to the Development Funds and Endowment, SMLLC.

Did I mention other “super powers”?

A SMLLC is a disregarded entity for all purposes of federal income tax law. It is, however, not a disregarded entity for all purposes of federal payroll tax law. Interesting!

One of the more common catastrophes of the not-for-profit world are payroll tax mismanagement. Catastrophic is the appropriate word. The Directors, members of the board, secretaries and payroll clerks and, in some cases, even banks, can be held responsible for unpaid payroll taxes and penalties. Harsh!

SMLLCs, Payroll and payroll tax functions

By placing all payroll and payroll tax functions into Operations and Management, SMLLC, and by crafting operating agreements and employee job descriptions carefully, it is possible that any payroll tax issues can be confined to that entity and to only a few designated (or perhaps, only one) individual who could be a designated “responsible party” for IRS purposes.

This could offer asset protection for the other related entities in the group and quickly move any payroll tax dispute onto the shoulders of the responsible party. This is not necessarily a bad outcome. Having agreements in place to indemnify any responsible party for payroll tax liabilities could quickly reduce payroll tax assessments to one-third (1/3) of the original assessment and thereby offer the consolidated entities a clear pathway to full financial recovery.

I have successfully worked this odd twist in payroll tax law three or four times in the past but never with a §501(c)(3) in the mix. I see no reason why it would not work just as well in the not-for-profit area of law.

Real Estate, SMLLC

The second entity from the above list is Real Estate, SMLLC. The function of this entity is to own land and buildings.

The management and maintenance of this real estate will be accomplished by Operations and Management, SMLLC. This second entity, Real Estate, SMLLC, is merely a real estate holding entity with no management or operational functions.

Equipment, SMLLC

The fourth and final entity from our list shown above is Equipment, SMLLC. This entity is for the sole purpose of owning all tangible property and equipment that is not land or buildings. This entity will have no management or operational functions for this entity.

Thrift Store #1, SMLLC and RBC Thrift Store #2, SMLLC

Even in the commercial world, separating retail operations by location is a common use of SMLLCs. The liabilities unique to retail are then confined to that location by the SMLLC. For example, a disastrous sales tax audit at the Attalla store can be confined to that store; the assets of the organization are protected. Likewise, a slip fall injury; etc.

Development Funds and Endowment, SMLLC

Each SMLLC can receive donations that are tax deductible. By using a SMLLC to hold and manage development and endowment funds, you isolate these funds from operations and create an additional layer of protection from the organization’s potential liabilities.

This organizational structure is helpful for special fund raising events, such as a capital fund campaign or to develop an endowment fund.

I have recently used this to avoid imminent litigation with profoundly positive results. Because an endowment fund can be its own SMLLC, it can have its own board of directors and the needed additional layer of liability protection.

In the recent case, successfully navigated by good entity and tax planning, I had to deal with potential litigants who were actually members of the board of directors of the parent organization! We caused a substantial (multimillion) contribution to be made to a new SMLLC for that purpose thus isolating these funds from the direct control of the renegade board members to a SMLLC (who had their own unique board) and accomplished two positive things:

  • Assets were protected and
  • The renegade board members regained perspective and fulfilled their board obligations admirably.

I am very fond of isolating development and endowment funds by use of SMLLC!

Management Issues

The organization delivers services as it always has; from the point of view of the children and the donors, nothing will appear to have changed. Internal management will change. These changes are not onerous.

  • Each SMLLC becomes what the law refers to as a fully integrated auxiliary of the parent organization. As such, each SMLLC is obligated to:
    • Make regular and routine financial reports to the management of the parent organization, in this case, Social Welfare Services, Inc.
      • This may require that Operations and Management, SMLLC make modest modifications to how the bookkeeping is accomplished.
      • Financial reports should be unique to the operations and function of the SMLLC to which they relate.
        • We can help set these up.
      • Also, each SMLLC is required to make operational and management reports to the parent organization.
        • Each SMLLC should have a report unique to the function of that SMLLC, for example, Real Estate, SMLLC should include two items, one for maintenance and the other for needed but deferred maintenance.
          • We can help set these up.
        • Each SMLLC can have a unique board of directors. Even with a unique board of directors, each SMLLC must report to the parent organization.

More Super Powers!

SMLLCs have a large variety of attributes and abilities that, in the right context, become super powers. The §501(c)(3) world offers a rich context to apply these abilities. A full list of these abilities are beyond the scope of this letter and, frankly, beyond my skill level and competence. That’s why I rely on outside legal counsel. By brain storming together, we and I have often discovered hidden applications for LLCs and SMLLCs that evolved into super powers.

A small list follows; each SMLLC can:

  • Have a unique EIN Number
    • This does not change how the IRS Form 990 is filed.
  • Have a separate bank account
    • Keeping money away from Social Welfare Services, Inc. is a good idea for reasons I will discuss in the next section of this letter.
  • Have a unique and separate board of directors.
    • This can be a good idea for a number of reasons; marketing is only one good reason.
    • A unique “junior” board of directors can groom the next generations of donors and management.

I promised a short list of alleged super powers; I have delivered. This list is too short by a large factor. Discovering new super powers that apply to your organization are where an ongoing relationship with a CPA Firm and an Attorney with deep skill sets in this area become important. None of us can anticipate all future situations. The attributes of LLCs and SMLLCs only become “super” with the right situation and timing. Going forward, that is our real job.

Liability Protection

The point of this proposed reorganization is asset protection. Each entity, including the parent entity, Social Welfare Services, Inc., enjoys a layer of liability protection.

Any meaningful discussion of liability protection through entity selection and management structure is the strict domain of attorneys. For that reason, I will ask our own attorney to review this letter and will allow him to make suggestions and, if he chooses to, make changes or add comments.

Social Welfare Services, Inc. is the provider of services to the children. If a child is hurt or killed in delivering these services, Social Welfare Services, Inc. will likely be a primary party in any legal action. Social Welfare Services, Inc. has no assets other than the limited funds in the operating bank account.

In the event that Social Welfare Services, Inc. is a party to a legal action, it is very likely that Operations and Management, SMLLC will also be named as a party to that legal action because it provides financial and personal management. To this point, the additional layer of protection from legal liability is thin. From the point of view of managing legal liability, it offers some but minimal additional protect. The mere fact that it is another legal entity complicates any potential plaintiff’s case.

For that reason, both Social Welfare Services, Inc. and Operations and Management, SMLLC should maintain minimal cash balances. All cash, not essential to day-by-day operations, should be held by Development Funds and Endowment, SMLLC.

Because Social Welfare Services, Inc. and Operations and Management, SMLLC does not own land, buildings or equipment, or the assets held by the Development Funds and Endowment, SMLLC they actually become a less attractive target for litigation.

The following entities:

  • Real Estate, SMLLC
  • Equipment, SMLLC
  • Thrift Store #1, SMLLC
  • RBC Thrift Store #2, SMLLC
  • Development Funds and Endowment, SMLLC

Because they are owned by a §501(c)(3), each of these entities will be important in achieving the goal of asset protection.

The purpose of LLC laws nationwide

LLC laws are now an important part of legal environment for businesses and not-for-profits in all fifty states. These laws were created were to offer liability protection to business owners and operations.

At the heart of the laws relating to LLC is the desire to accomplish liability protection for businesses and §501(c)(3), business owners, directors and employees.

This letter is not a radical or new interpretation of the law; this letter addresses the heart and purpose of LLC laws. State LLC laws and federal tax laws have made in clear that LLCs and SMLLC apply to not-for-profit organizations; again, I am not bending or twisting the law.

My letter is a mainstream application of the law. This is not risky or pioneering legal or tax work, this is simply an application of the law!

Conclusion

I enjoy working with §501(c)(3) organizations. Our CPA Firm has more than a few such organizations. In general, these organization have deep convictions that their work is essential. In your case, caring for children, especially boys, is essential!

Your need to protect assets is 100% driven by your desire to see that these children receive essential services in the future.

I am 100% committed to helping you accomplish that task!

Sincerely,

Steve Richardson, CPA

For the Firm

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