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December 2007
Vol. 1 • No. 1
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December 2007
Vol. 1 • No. 1
2007 AICPA National tant that bond monitoring be set up the user at the flat rate charged for
Not-For-Profit Industry as a well-documented process that additional minutes. The organization
is performed regularly so that when that did it this way had only 20 users.
Conference changes occur, the system is there to Another attendee from a much larger
continued from page 1 catch violations. organization said that they would
affecting nonprofits, but also to hear have to hire a dedicated employee
The IRS does perform compliance just to deal with cell phone expense
about real-life experiences from audits of bond issues and, in the
other attendees. Here are some of the allocations. In response, one of the
future, they will be sending ques- presenters suggested they do what
very interesting tidbits I picked up tionnaires to a sample of borrow-
this year. others have done: give an allowance
ers. Regular monitoring will help and gross up for the taxes and have
you if you are selected for audit or the users purchase their own phones
Tax Exempt Bond Monitoring the sample. and plans. Practical and compliant.
As any of you who have gone Finally, the proposed new IRS Form
through the process of borrowing via 990 has a Schedule K that asks for SAS 112
a tax exempt bond issuance know, information on tax exempt bonds.
there is a lot you must do to success- Last year we learned at the confer-
Cliff Gannett, the Director of the Tax ence about the upcoming changes to
fully complete the transaction. Most Exempt Bonds Division of the IRS
likely, you focused on the paperwork the management letter. I reported to
and co-presenter of this session, said you that auditors would have more
for months. Then you went to settle- that they will be using this Schedule
ment. You had your financing and findings than in the past. A very
to aid in their enforcement efforts. important concept was the auditor
you could relax. Or could you?
could not be part of an organiza-
The big message of this session is Personal Use of Cell Phones tion’s internal controls over finan-
that organizations cannot relax. I told you about this issue last year cial reporting. The session on SAS
There are things to do and remem- and during the year I received numer- 112 this year was very interesting
ber throughout the life of the financ- ous phone calls from clients asking for because we have been living with it
ing and beyond. a practical method of tracking person- for several months now. Attendees
al use of cell phones. I did not have from organizations confirmed that
For example: 1) Records, including all there were more comments, as did
invoices supporting qualified expen- one. Well, given the turnout for this
session and the ensuing discussion, it the auditors. One point emphasized
ditures, must be retained for the life is that it is not a bad thing for the
of the financing, plus three years. 2) appears that it isn’t only my clients
having trouble figuring a way to be auditee to call the auditor through-
Someone must monitor issuance out the year to discuss issues. That
costs and make sure that last-minute both compliant and practical.
Unfortunately, the presenters did not may demonstrate that the organiza-
fees do not throw the total outside the tion is appropriately assessing the
allowable range of two percent. 3) offer a practical solution. However
they did identify methods they felt risk of certain transactions with
Someone must be vigilant over the respect to financial reporting.
use of the property over the years. would not be approved by the IRS.
The property must be used only for So, in lieu of direct guidance on what On a personal note, I had dinner
exempt purpose of the 501(c)(3): no to do, here’s a list of what not to do: with an acquaintance who manages
unrelated business activity, no pri- 1) Issue a blanket written statement a foundation. She was somewhat
vate use, no religious use. 4) Someone to users that all personal use is pro- upset that she had received a man-
must monitor the life of the property hibited. 2) Add a flat annual amount agement letter with significant defi-
purchased with the proceeds and to the user’s W-2, irrespective of ciencies as she had never been writ-
make sure that payback is timed so usage. 3) Apply a flat percent to all ten up in the past. In addition to a
that the life of the issue is less than invoices and add that to the user’s deficiency because of auditor pro-
120 percent of the life of the project. W-2, irrespective of usage. 4) Charge posed AJEs, one comment related to
the user for any fees in excess of the management’s lack of monitoring of
None of this seems that difficult. its alternative investment portfolio.
flat monthly fee levied under the
However, think about the transi-
organization’s plan.
tions that occur in organizations That’s all for this issue. Stay tuned.
over 15 or 20 years: boards and A method that would be approved is In our next newsletter, I’ll be sharing
management change, revenue to have the user analyze each invoice tidbits about alternative invest-
streams change, the world changes, and document business use. The per- ments that I gathered at the recent
missions change. It is very impor- sonal minutes would be charged to AICPA conference.