Earlier today, the Senate unanimously approved H.R. 7010, a bill that will dramatically alter several critical terms of the recently-enacted Paycheck Protection Program (PPP). The bill, which passed the House last week and now heads to the President’s desk for signature, will provide much needed relief for borrowers as they seek forgiveness of their loan amounts.
WASHINGTON, DC – APRIL 28: White House press secretary Kayleigh McEnany listens as U.S. President … [+]
GETTY IMAGES
But before we get into the details, let’s remember how we got here…
On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security (CARES) Act, a $2.3 trillion relief package designed to help individuals and businesses weather the economic damage caused by the COVID-19 pandemic.
The headliner of the CARES Act was the creation of the PPP, a new loan package designed to put nearly $600 billion into the hands of small businesses for use in paying employee wages and other critical expenses over the coming weeks and months. But as was the case with Ask Jeeves and McDonald’s Mighty Wings, the shortcoming of the PPP was not its motivation, but rather its execution.
HEROES Act Would Expand The EITC For Childless Workers And Help Fight Recession
Paycheck Protection Forgiveness Just Got Easier
SCOTUS Deliberates Trump’s Tax Returns
It’s been one disaster after another, and there is plenty of blame to go around, from the writers of the CARES Act and Congressional leaders to the Small Business Administration and the IRS. Here’s just a small taste of what’s gone wrong:
When the program opened on April 3rd, many big banks weren’t ready to accept applications, and of those that were, many more were only willing to work with borrowers with whom they had a preexisting relationship, shutting out the very small business owners the PPP was designed to help.
Once the loans got going, a bit of bad publicity led to some revisionist history. The CARES Act provided that to obtain a PPP loan, a borrower simply had to certify that “economic uncertainty” made the loan necessary, which given the impact of COVID-19, included, well…everyone. In addition, the Act made special accommodations for the hard-hit hotel and food service industry. But when Ruth’s Chris and a couple of big fast-food chains came and claimed their PPP loans — rightfully, I might add — the How Did This Industry Gian Get a Loan Intended for Small Businesses? articles began to roll in, and Congress and the SBA panicked. Senator Rubio promised to use subpoena power to expose businesses who got a loan that weren’t “deserving.” Treasury Secretary Mnuchin promised to make public a list of all businesses who took out a PPP loan. And the SBA pivoted from the forgiving certification requirement in the CARES Act, now requiring every borrower to be prepared to prove they had no other sufficient sources of liquidity, and thus needed the loans to survive. Businesses were urged to return their loans lest they be publicly shamed, and many did, only for the SBA to state the DAY BEFORE THE DEADLINE TO REPAY that loans under $2 million would not be subject to scrutiny. That news, as you can imagine, came too late for some who had returned funds they had every right to obtain. A nightmare all around.
The IRS had its fun as well. The CARES Act specifically provides when a borrower has a PPP loan forgiven, the forgiveness does not generate taxable income. Over a month later, well after many businesses had obtained their loans, the Service (correctly) applied the laws of the Internal Revenue Code to state that while the forgiveness may not be taxable, any expenses paid with forgiven funds would NOT be deductible. A few members of Congress briefly put up a fight, but once that fizzled, borrowers were left with an after-tax return on the loan that was much different than what they had planned.
And of course, the guidance from the SBA interpreting the PPP has been untimely, inconsistent, and incomplete. Weeks into the program, no one understood how to compute a borrower’s loan proceeds. Rules for self-employed taxpayers weren’t available until the first round of funds were depleted. Countless partnerships borrowed amounts based only on employee payroll costs, only to later be told that they should have included partner compensation. And while the CARES Act placed no limitation on the amount of forgivable costs attributable to non-payroll costs, the SBA stepped in and capped it at 25%. It’s been a circus.
Most maddening of all, rules governing the forgiveness of a PPP loan — which is ultimately all every borrower cares about — were delivered nearly THREE WEEKS late. There was so much confusion about what was and wasn’t forgivable that I once spent 7,000 words writing what we didn’t know about forgiveness.
To top it all of, now that banks, business owners and bean counters have spent tens of thousands of hours making sense of what little rules exist, Congress has changed many of them. But…that’s OK. Congress had to do it. The reality is, the CARES Act was written with the hope that by now, America would be fully open and business would be booming again. Unfortunately, that is not the case. Borrowers definitely needed relief, and kudos to Congress for getting it done. All’s well that ends well, as they say.
So let’s take a look at what H.R. 7010 has to offer, but if you’re new to PPP loans (you are not), I’d encourage you to first read this.
You’ll have longer to repay any loan proceeds that are not forgiven
After passage of the CARES Act, the SBA assigned a 2-year maturity date to the portion of any PPP loan that was not forgiven. H.R. 7010 extends this period to five years. While technically, this prolonged repayment period applies only to PPP loans made AFTER passage of the bill, lenders and borrowers are free to renegotiate the terms of any existing PPP loan to match the permitted 5-year period.
In addition, while the CARES Act required lenders to defer the payment of principal and interest for six months, H.R. 7010 allows for deferral until the date the lender receives the forgiveness amount from the SBA, which in most cases will be significantly longer.
Forgiveness is much easier to come by
This is what business were clamoring for. H.R. 7010 will greatly increase the likelihood that a large percentage of a borrower’s PPP loan will be forgiven. It does so in four ways.
1 Extension of covered period
First, as we mentioned above, the CARES Act granted borrowers eight weeks from the moment they received the PPP proceeds to incur costs eligible for forgiveness. H.R. 7010, however, extends that “covered period” to 24 weeks from the date of the loan’s origination, or December 31, 2020, whichever comes earlier.
This move was critical because while the CARES Act was built on the hope that most businesses would be up and running by now, the reality is that many bars, restaurants, hotels and other businesses are nearing the end of their initial 8-week covered period only to remain partially or fully suspended by state or local order. More time to incur forgivable costs is essential, and Congress has supplied just that.
Of course, limits remain. The maximum amount paid to any one employee that will be forgiven is capped at an annualized salary of $100,000; as a result, for a 24-week covered period, this limit will be reached once an employee receives $46,153 in cash compensation. H.R. 7010 does not make that clear, but here’s to hoping that soon-to-be-released guidance does.
2 You can spend more of your proceeds on non-payroll costs, but BE CAREFUL
The expanded covered period pulls FOUR MONTHS of additional mortgage interest, rent and utility costs into the forgiveness fold, a move that, in isolation, would have been of limited usefulness given that the SBA limits the portion of a borrower’s forgivable expenses attributable to these types of non-payroll costs to 25% of the total.
Fortunately, H.R. 7010 remedies this problem as well, though not without a potentially terrifying trap for the unwary. The new bill provides that the 25% cap for non-payroll costs is raised to 40%, which is great news for borrowers.
But here’s what’s really, really, bad: the bill states that “to receive loan forgiveness under this section, an eligible recipient shall use at least 60 percent of the covered loan amount for payroll costs….”
That language is…uncomfortable. Sure, the SBA capped forgiveness attributable to non-payroll costs at 25%, but the SBA doesn’t care how much of the borrowed proceeds you spend. If you borrowed $100,000 and spent $50,000 on payroll costs and $30,000 on non-payroll costs, your total forgivable costs would be limited to $66,667 ($50,000/75%), but you’d still get that $66,667 of forgiveness.
To the contrary, H.R. 7010 appears to create a cliff: if a borrower fails to spend 60% of the loan proceeds on payroll costs, NONE of the loan will be forgivable. In the example above, because only $50,000 of the proceeds (50%) were spent on payroll costs, NONE of the loan would be forgiven. In effect, borrowers are trading a longer covered period for the requirement that 60% of the proceeds be spent during that time to maintain payroll.
It should be noted that Senator Marco Rubio, among others, are not comfortable with this cliff effect, and have asked the SBA to address the issue favorably in regulations. I’m not sure what type of wiggle room they’ll have given the statutory language, but when you consider that the SBA pretty much took a blowtorch to the legislative text of the CARES Act, I guess anything is possible.
3 You’ll have longer to replace FTEs/restore salaries
As we’ve previously discussed at great length here, a borrower can spend every last penny of its PPP loan on payroll costs, and still will not have the entire loan forgiven if either:
The borrower lost full-time equivalent employees (FTEs) during the covered period relative to one of several base periods, or
The borrower significantly reduced the average annual salary or hourly wage of certain employees during the covered period relative to the first quarter of 2020.
In either scenario, however, the borrower could restore any reduction in the forgiveness amount if it either fully restored FTEs or salary/hourly wage to their February 15th, 2020 levels before June 30, 2020. The problem, of course, is as discussed above, many businesses are nowhere close to being fully staffed, and likely won’t be before June 30th.
H.R. 7010 solves this issue by extending the June 30th deadline to December 31, 2020. Thus, as long as the FTEs or salary/hourly wage are restored to February 15th levels any time prior to the end of 2020, no reduction in forgiveness will be required.
4 Businesses that remain partially or fully closed through the end of the year will get new relief
Finally, H.R. 7010 offers a new way out for borrowers who lose FTEs. The bill provides that during the period beginning on February 15, 2020, and ending on December 31, 2020, the amount of loan forgiveness will NOT be reduced when a borrower experiences a loss of FTEs if the borrower, in good faith, is able to document any of the below:
There was an inability to rehire individuals who were employees of the eligible recipient on February 15th,
There was an inability to hire similarly qualified employees for unfilled positions on or before December 31, 2020, or,
There was an inability to return to the same level of business activity as such business was operating at before February 15th due to compliance with requirements established or guidance issued by the Secretary of Health and Human Services, the Director of the Centers for Disease Control and Prevention, or the Occupational Safety and Health Administration during the period beginning on March 21 1, 2020, and ending December 31, 2020, related to the maintenance of standards for sanitation, social distancing, or any other worker or customer safety requirement related to COVID– 19. This is the BIG ONE. It basically provides that if the world is such that on December 31st, restaurants and bars, for example, are unable to fully open due to government orders, any loss in FTEs resulting from such restrictions should NOT be taken into account in computing a required reduction in the forgivable amount.
The 8-week covered period remains an option
H.R. 7010 does not require all borrowers to adopt a 24-week covered period. To the contrary, any business that borrowed its PPP loan prior to the date the bill is signed into law can elect to use the 8-week period beginning on the date it received the funds. This will appeal to those businesses who have spent all of their proceeds and qualify for full forgiveness and who do not wish to wait until the end of the year to apply.
You can now defer certain payroll taxes even if you received a PPP loan
The CARES Act wasn’t ONLY about PPP loans, you know. An additional incentive allowed employers to defer the employer’s 6.2% share of 2020 Social Security tax until the end of 2021 (50%) and 2022 (50%). This deferral was only available, however, to a borrower of a PPP loan until the moment the loan is forgiven.
H.R. 7010 allows an employer to double dip; a borrower of a PPP loan may now also defer all of its 2020 Social Security tax burden into 2021 and 2022, even if the PPP loan is forgiven prior to December 31, 2020.
Questions Remain
H.R. 7010 is unequally great news for borrowers. But there are still some sources of confusion:
We presumed above that the limit of cash compensation per employee would increase in proportion to the increase in the covered period, from $15,385 to $46,153. But is that really the case?
If it IS the case, will the limit on forgivable compensation to owner-employee increase in lockstep? Recent guidance from the SBA states that the maximum amount of forgivable compensation paid to an as-yet-undefined “owner-employee” is capped at 8/52 of the 2019 compensation amount. Is that formula now increased to 24/52?
What is to be done with self-employed taxpayers? As a reminder, a Schedule C filer’s forgiveness for payroll costs is purely mechanical; it was previously defined as 8/52 of Line 31 of the 2019 Form Schedule C. Is that fraction now also 24/52? If so, full forgiveness for all self-employed taxpayers with no employees should be mathematically guaranteed.
Will borrowers be required to wait until the end of a 24-week covered period to apply for forgiveness? If the funds are fully spent by, say, mid-September, and FTEs and salaries are at February 15th levels, can a borrower apply at that time, even though the covered period hasn’t ended?
I ask the previous question because here’s what bothers me most: As we found out a month go, expenses paid with PPP proceeds that are ultimately forgiven will NOT be deductible to the borrower. But with the covered period now running until the end of the year — and with borrowers having what appears to be up to ten months to apply for forgiveness — it is possible that 2020 tax returns will be filed PRIOR to determining the forgivable amount. An obvious conundrum arises: how can we know the amount of expenses that are nondeductible on the 2020 return if we don’t know the amount of the loan that is forgiven? Perhaps the answer is that all amounts will be fully deductible in 2020, with an adjustment made on the 2021 return to effectively include the forgiven amount in income; a result that doesn’t align with the intended consequence of paying expense with tax-exempt income, and that may have implications on other aspects of a business owner’s tax return (Section 199A, anyone)?
Nearly two weeks ago, the rumor was that the SBA was sitting on 30 FAQs that would provide much needed guidance. Those FAQs were never released, presumably because the SBA was keeping a watchful eye on Capitol Hill.
With H.R. 7010 set to be signed by the President, however, there’s no longer reason to wait; the SBA should quickly release its (presumably updated) FAQs and allow us to mercifully put this PPP debacle behind us.
Contact us for any questions or for more information.
On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). The Act includes various provisions designed to provide an economic stimulus to both individuals and businesses. The intention of the new legislation is to increase cash flow and liquidity and to reduce the cost of capital.
The various provisions of the Act will accomplish those goals and assist in the long-term recovery of our economy:
Various other tax provisions aimed at economic recovery such as the expanded use of Net Operating Losses and an increased deduction for business interest expense
The application to individuals and businesses varies depending upon each person’s specific circumstances. Some of the provisions prohibit the participation in various other programs or limit the availability of credits, etc. We are monitoring information coming from various sources and learning as much as we can about the Act so that we may assist you. Final regulations are set to be issued Friday, April 3rd which will provide additional clarification. Please call or email us with your questions or concerns about how this will affect you. At JSA, we stand ready to help our clients get through this unprecedented situation.
As a result of the increase in coronavirus cases in Arkansas and to keep our staff healthy, we are now all working remotely. We are all available via email or phone. We will continue to provide the same excellent service you are used to. All information, including tax returns, will be delivered electronically and tax information will be mailed to you using the US Postal Service. For those who do not use e-mail, your information will be mailed to you.
Our hearts are heavy for those of you who have been impacted by the coronavirus. We continue to pray for all of you. Please stay safe and healthy during this time!
WASHINGTON — To help people facing the challenges of COVID-19 issues, the Internal Revenue Service announced today a sweeping series of steps to assist taxpayers by providing relief on a variety of issues ranging from easing payment guidelines to postponing compliance actions.
“The IRS is taking extraordinary steps to help the people of our country,” said IRS Commissioner Chuck Rettig. “In addition to extending tax deadlines and working on new legislation, the IRS is pursuing unprecedented actions to ease the burden on people facing tax issues. During this difficult time, we want people working together, focused on their well-being, helping each other and others less fortunate.”
“The new IRS People First Initiative provides immediate relief to help people facing uncertainty over taxes,” Rettig added “We are temporarily adjusting our processes to help people and businesses during these uncertain times. We are facing this together, and we want to be part of the solution to improve the lives of all people in our country.”
These new changes include issues ranging from postponing certain payments related to Installment Agreements and Offers in Compromise to collection and limiting certain enforcement actions. The IRS will be temporarily modifying the following activities as soon as possible; the projected start date will be April 1 and the effort will initially run through July 15. During this period, to the maximum extent possible, the IRS will avoid in-person contacts. However, the IRS will continue to take steps where necessary to protect all applicable statutes of limitations.
“IRS employees care about our people and our country, and they have a strong desire to help improve this situation,” Rettig said. “These new actions reflect just one of many ways our employees are working hard every day to assist the nation. We care, a lot. IRS employees are actively engaged, and they have always delivered for their communities and our country. The People First Initiative is designed to help people take care of themselves and is a key part of our ongoing response to the coronavirus effort.”
More specifics about the implementation of these provisions will be shared soon. Highlights of the key actions in the IRS People First Initiative include:
Existing Installment Agreements –For taxpayers under an existing Installment Agreement, payments due between April 1 and July 15, 2020 are suspended. Taxpayers who are currently unable to comply with the terms of an Installment Payment Agreement, including a Direct Deposit Installment Agreement, may suspend payments during this period if they prefer. Furthermore, the IRS will not default any Installment Agreements during this period. By law, interest will continue to accrue on any unpaid balances.
New Installment Agreements – The IRS reminds people unable to fully pay their federal taxes that they can resolve outstanding liabilities by entering into a monthly payment agreement with the IRS. See IRS.gov for further information.
Offers in Compromise (OIC) – The IRS is taking several steps to assist taxpayers in various stages of the OIC process:
Pending OIC applications – The IRS will allow taxpayers until July 15 to provide requested additional information to support a pending OIC. In addition, the IRS will not close any pending OIC request before July 15, 2020, without the taxpayer’s consent.
OIC Payments – Taxpayers have the option of suspending all payments on accepted OICs until July 15, 2020, although by law interest will continue to accrue on any unpaid balances.
Delinquent Return Filings – The IRS will not default an OIC for those taxpayers who are delinquent in filing their tax return for tax year 2018. However, taxpayers should file any delinquent 2018 return (and their 2019 return) on or before July 15, 2020.
New OIC Applications – The IRS reminds people facing a liability exceeding their net worth that the OIC process is designed to resolve outstanding tax liabilities by providing a “Fresh Start.” Further information is available at IRS.gov
Non-Filers –The IRS reminds people who have not filed their return for tax years before 2019 that they should file their delinquent returns. More than 1 million households that haven’t filed tax returns during the last three years are actually owed refunds; they still have time to claim these refunds. Many should consider contacting a tax professional to consider various available options since the time to receive such refunds is limited by statute. Once delinquent returns have been filed, taxpayers with a tax liability should consider taking the opportunity to resolve any outstanding liabilities by entering into an Installment Agreement or an Offer in Compromise with the IRS to obtain a “Fresh Start.” See IRS.gov for further information.
Field Collection Activities – Liens and levies (including any seizures of a personal residence) initiated by field revenue officers will be suspended during this period. However, field revenue officers will continue to pursue high-income non-filers and perform other similar activities where warranted.
Automated Liens and Levies – New automatic, systemic liens and levies will be suspended during this period.
Passport Certifications to the StateDepartment – IRS will suspend new certifications to the Department of State for taxpayers who are “seriously delinquent” during this period. These taxpayers are encouraged to submit a request for an Installment Agreement or, if applicable, an OIC during this period. Certification prevents taxpayers from receiving or renewing passports.
Private Debt Collection – New delinquent accounts will not be forwarded by the IRS to private collection agencies to work during this period.
Field, Office and Correspondence Audits – During this period, the IRS will generally not start new field, office and correspondence examinations. We will continue to work refund claims where possible, without in-person contact. However, the IRS may start new examinations where deemed necessary to protect the government’s interest in preserving the applicable statute of limitations.
In-Person Meetings – In-person meetings regarding current field, office and correspondence examinations will be suspended. Even though IRS examiners will not hold in-person meetings, they will continue their examinations remotely, where possible. To facilitate the progress of open examinations, taxpayers are encouraged to respond to any requests for information they already have received – or may receive – on all examination activity during this period if they are able to do so.
Unique Situations – Particularly for some corporate and business taxpayers, the IRS understands that there may be instances where the taxpayers desire to begin an examination while people and records are available and respective staffs have capacity. In those instances when it’s in the best interest of both parties and appropriate personnel are available, the IRS may initiate activities to move forward with an examination — understanding that COVID-19 developments could later reduce activities for an agreed period.
General Requests for Information – In addition to compliance activities and examinations, the IRS encourages taxpayers to respond to any other IRS correspondence requesting additional information during this time if possible.
Earned Income Tax Credit and Wage Verification Reviews – Taxpayers have until July 15, 2020, to respond to the IRS to verify that they qualify for the Earned Income Tax Credit or to verify their income. These taxpayers are encouraged to exercise their best efforts to obtain and submit all requested information, and if unable to do so, please reach out to the IRS indicating the reason such information is not available. Until July 15, 2020, the IRS will not deny these credits for a failure to provide requested information.
Independent Office of Appeals – Appeals employees will continue to work their cases. Although Appeals is not currently holding in-person conferences with taxpayers, conferences may be held over the telephone or by videoconference. Taxpayers are encouraged to promptly respond to any outstanding requests for information for all cases in the Independent Office of Appeals.
Statute of Limitations – The IRS will continue to take steps where necessary to protect all applicable statutes of limitations. In instances where statute expirations might be jeopardized during this period, taxpayers are encouraged to cooperate in extending such statutes. Otherwise, the IRS will issue Notices of Deficiency and pursue other similar actions to protect the interests of the government in preserving such statutes. Where a statutory period is not set to expire during 2020, the IRS is unlikely to pursue the foregoing actions until at least July 15, 2020.
Practitioner Priority Service – Practitioners are reminded that, depending on staffing levels and allocations going forward, there may be more significant wait times for the PPS. The IRS will continue to monitor this as situations develop.
“The IRS will continue to review and, where appropriate, modify or expand the People First Initiative as we continue reviewing our programs and receive feedback from others,” Rettig said. “We are committed to helping people get through this period, and our employees will remain focused on these and other helpful efforts in the days and weeks ahead. I ask for your personal support, your understanding – and your patience – as we navigate our way forward together. Stay safe and take care of your families, friends and others.”
Treasury Secretary Steven Mnuchin, “All taxpayers and businesses will have this additional time to file and make payments without interest or penalties.”
The news today is dominated by information about the COVID-19 virus. Our heartfelt sympathies go out to those who have been affected by the coronavirus-those affected physically and economically.
At JSA, we are blessed to have not been affected directly by COVID-19 yet. It seems we all know someone who has felt the impact. Our mission is to make sure that any impact to our clients is minimal. We are also concerned about protecting our staff.
For several years, we have been paperless and have the ability to work remotely. We are deep into ‘tax season’ and will be meeting filing deadlines as they come due. We ask for your patience during this time as we too are working through how to best handle the situation. There will, however, be some unforeseen impacts. Ultimately, our goal is to continue to serve our clients.
In order to prevent any contamination from COVID-19, we have instituted the following measures:
1. All deliverables will be sent electronically. This includes tax returns and other items. Paper copies will be mailed to you along with any paperwork provided to us.
2. We will not be meeting with clients face-to-face at least thru the end of ‘tax season.’ We will conduct meetings via video conference or FaceTime.
3. If you are not able to send your information to us electronically, please mail it to the office. We ask that you not come to the office. While we love seeing all of our clients, we feel it is in everyone’s best interests to avoid social contact for the time being.
We continue to practice good hygiene at the office. We ask that you do the same. Although our offices are cleaned twice a week, we have taken extra precautions to wipe down all door handles/knobs, desks, chairs and flat surfaces in the common areas of the building. Each member of our team is also diligent in keeping their office clean.
We will continue to monitor the situation and will keep you informed of any changes we make in response to the COVID-19 virus. As always, please let us know how we can serve you and if you have any questions. We appreciate your continued trust in us and look forward to providing you with excellent service and value.
On Wednesday, the IRS issued guidance clarifying the ability to deduct meals in light of the changes brought about by the Tax Cuts and Jobs Act. Please click on the link which will take you to the article. Please contact us or call the office at your convenience if you have any questions-we’d be happy to discuss this with you. (501) 372-4180
Local CPA firm in Little Rock seeking to fill senior staff accountant position. CPA or CPA-qualified candidate. The qualified candidate will have 2-3 years of recent public accounting experience with supervisory skills a plus. Position requires skills in both income tax and financial statement preparation. Must have excellent problem solving skills with limited supervision. This person will have a “get it done” mentality and supervise staff to meet deadlines. We are committed to providing a work/life balance for our employees and offer flexible hours for a candidate looking for a full- or part-time position. The firm offers an excellent benefits package including retirement plan, health insurance and cafeteria plan. Compensation based upon experience. No travel required.Full-time, Part-timeApply Now
Johnson Smith and Associates – Our office has received a few phone calls where the caller has indicated they received a call or a voicemail stating that someone with Johnson, Smith and Associates would be hand-delivering some important documents to their residence and they needed to verify that someone above the age of 18 would be home. Either there was no number left for a return call or no valid phone number appeared on caller id, so the recipients of these calls Googled “Johnson, Smith and Associates”, and got our firm. This company has also left the call back number of (888) 742-6869 and (888) 789-2498. The company in question is a legitimate company out of Massachusetts, and is inno way related to JSA CPAs, PLLC (formerly Johnson, Smith & Associates, PLLC), in Little Rock, Arkansas.
As some of you may have noticed, we recently changed our name!! Johnson, Smith & Associates, PLLC is now JSA CPAs, PLLC! We will still be providing the same exceptional services which you have come to depend on us for. Our office location, phone, and fax numbers will remain the same. Our website is now www.jsacpas.net. As always, we look forward to the upcoming year and wish everyone a very Merry Christmas and a Happy New Year!