AZ CPA Oct. 2019

AZ CPA October 2019

Technology and the CPA

The Future of Fraud in Technology Data Analytics Implementation in Accounting Firms The Art of Gaming

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OCTOBER 2019 AZ CPA

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AZ CPA The Arizona Society of Certified Public Accountants President & CEO Editor Advertising

Cindie Hubiak Patricia Gannon Heidi Frei

Board of Directors Chair Jared Van Arsdale Chair-Elect Ginny DeSanto Secretary/Treasurer Tom Duensing Directors

Rachael Bertrandt

Keith Cowan

Kelly Damron

Paul Evans

Ross Grainger

Tim Hansen

Jessica Iennarella

Andrea Levy

Anthony Lorenzo

Vanessa Makridis

Karen McCloskey

Sami Raynes-Houseknecht

Immediate Past Chair Mike Allen AICPA Council Members Rob Dubberly

Greg Nelson Chapter Presidents Southern Chapter Cathy Kinzer Northern Chapter James Shankland Southwest Chapter Helen Greenwell North-Central Chapter Gidget Schutte AZ CPA is published by the Arizona Society of Certified Public Accountants (ASCPA) to provide information, news and trends to the accounting profession. It is distributed 10 times a year as a regular service to ASCPA members. The ASCPA, its members, board of directors and administrative staff assume no responsibility for advertisements herein.

The ASCPA and the above people also assume no liability for business decisions made by readers in reference to statements and/or claims in articles or advertisements within this publication. Opinions expressed by contributors are not necessarily those of the ASCPA.

Arizona Society of CPAs 4801 E. Washington St., Suite 180 Phoenix, AZ 85034-2040 Telephone (602) 252-4144 AZ Toll-Free (888) 237-0700 www.ascpa.com

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AZ CPA OCTOBER 2019

Volume 35 Number 8

AZ CPA

October 2019

Features

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Dancing With the Choice ASCPA member Martin Gaxiola, CPA, has two quite different careers — accounting and Flamenco dancing.

by Patty Gannon

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The Future of Fraud in Technology Technology makes us better CPAs, but can also be used by criminals for increasingly creative scams.

by Dr. Robert K. Minniti, CPA

15 Columns & Departments Chair’s Message by Jared Van Arsdale, CPA

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Member News

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A Dash of SALT by James G. Busby, Jr., CPA

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Quick Quiz

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Classifieds 22

Data Analytics Implementation in Accounting Firms Accounting firms are focusing on using data analytics to increase the quality of their auditing procedures.

by Virginia Collins

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The Art of Gaming: What Our Internal Controls Fail to Catch Human nature, combined with technology and lack of internal controls, can make for some interesting fraud schemes.

by Marianne M. Jennings

Arizona Society of Certified Public Accountants 4801 E. Washington St., Suite 180 Phoenix, Arizona 85034-2040 www.ascpa.com

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ASCPA Chair’s Message

The Profession of Tomorrow Recently, I have been reading obsessively about the 2010 Flash Crash of the U.S. stock market. Why? I honestly cannot recall. I often revisit ideas, articles, quotes and stories with little point of reference on where the content was sourced originally. It could have been a book I read relating to historical stock market crashes or a random Financial Times article. Nonetheless, the event keeps resonating because it provides me with a very brief moment in time to point to as an example of an industry’s technological experimentation.

by Jared Van Arsdale, CPA For the betterment of our future organizations and to ensure the future relevance of our profession, I would encourage all of us to set aside some small amount of resources to explore how technological disruptions could impact your practice, your organizations and the CPA profession as a whole.

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I latched onto one theory of the cause of the 2010 Flash Crash in particular. The theory alleged that a single Kansas-based firm initiated a computerized algorithm to sell a total of 75,000 S&P futures contracts valued at $4 billion in several chunks every minute starting at 2:32 p.m. on May 6, 2010. A reasonable action as the news of the week was the possible default of the nation of Greece on its sovereign debt. Unknowingly, the algorithm contained a potential flaw where the sales in the current minutes were contingent on the volume of trades in the previous minute but without regard to the sales price of those trades. The algorithmic trades resulted in a millisecond by millisecond cycle of trades with other computerized high-frequency traders that drove the price of S&P futures contracts, and many corporate stocks, uncontrollably downward. Stocks like Accenture PLC (a consulting firm spun off from Arthur Andersen) traded down from $40 a share to $0.01 in a matter of minutes.

At 2:45 p.m., 13 minutes later, the Chicago Mercantile Exchange halted trading for five seconds (more than enough time for the algorithm to catch its breath I guess) beginning the market’s rebound. Per an SEC and CFTC report on the event, by 3 p.m. most stocks had returned to their pre-crash trading value. All within 28 minutes.

What I find absolutely amazing about the 2010 Flash Crash was the level of loss realized and the dramatic amount of opportunity experienced in a matter of minutes.

If you decided to get up for a coffee or take a call, you missed it. However, for those full engaged and actively observing the market, those few minutes could have been a terrific opportunity to invest in the future.

Revisiting this event repeatedly reinforces my understanding that our profession is not immune from downward economic cycles, nor is it lacking substantial opportunities for reinvestment in future technologies. A short time ago, the outsourcing of labor and skills was limited to the commuting radius of our offices. We are now boundless global organizations enhanced by developments in communication and data sharing tools. Notably, the AICPA and other professional organizations have already been exploring the impact algorithm, artificial intelligence and blockchain technology may have on the internal and external audits of the future.

As a profession, we can be corralled into the boundaries of our today. Fenced within the walls of our offices, limited to the availability of our calendar and focused on the maximization of our team’s productivity for short-term goals. For the betterment of our future organizations and to ensure the future relevance of our profession, I would encourage all of us to set aside some small amount of resources to explore how technological disruptions could impact your practice, your organizations and the CPA profession as a whole. Get ready to participate in the profession of tomorrow.n

Member News

ASCPA Life member James M. Susa, CPA, was selected by his peers for inclusion in the 26th Edition of The Best Lawyers in America for his work in tax law. He additionally was recognized as one of the 2020 “Lawyer of the Year” award recipients.

Stuart P. Wiemers, CPA, was admitted as a partner to Lohman Company, LLC.

Watch for the ASCPA’s New Brand Coming soon!

Some of our members involved in our advocacy efforts were featured in a recent photo shoot at the Capitol. This is part of the updates that we are working on as we get closer to unveiling our new brand in November.

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A Dash of SALT

Arizona Wayfair Law Perpetuates Some State/City Differences - Pt. 2 In this month’s state and local tax (SALT) column, Busby highlights the differences that will remain between Arizona’s state and city sales tax bases now that the provisions of H.B. 2757 that relate to Arizona’s new economic nexus standards for remote sellers and marketplace facilitators are in effect.

This is the second in a series of three articles addressing Arizona’s response to the Wayfair decision.

As noted in my last column, Arizona recently amended its tax code to require remote sellers to remit sales tax on proceeds from sales to in-state customers based on economic nexus, adopted marketplace facilitator provisions and preempted localities from imposing retail sales taxes under their own tax codes.

The municipal preemption dramatically simplify the state’s sales tax structure under which 91 cities and towns used to impose retail sales taxes under their own tax codes. But many differences remain between the state tax base and the tax bases for various cities and towns.

Exemptions and Optional Items The only municipal-only sales tax exemption that the Legislature added to the sales and use tax statutes is for paintings, sculptures or similar works of fine art sold by their original artist.

Lawmakers also permitted municipalities with an option to impose sales and use taxes on up to 10 categories of items that the state exempts, including: 1. food for home consumption sold by grocers, through vending machines, or by other types of retailers; 2. textbooks required by any state university or community college sold by bookstores; 3. propagative materials sold to persons who use them to commercially produce agricultural, horticultural, viticultural or floricultural crops in the state; 4. livestock and poultry feed, salts, vitamins and other additives for livestock or poultry consumption that are sold to persons for use or consumption by their own livestock or poultry, for use or consumption in the business of farming, ranching and producing or feeding livestock, poultry or livestock or poultry products or for use or consumption in noncommercial boarding of livestock; 5. implants used as growth promotants and injectable medicines, not already exempt under a particular provision of state law, for livestock or poultry owned by or in possession of persons who are engaged in producing livestock, poultry or livestock or poultry products or who are engaged in feeding livestock or poultry commercially;

by James G. Busby, Jr., CPA

James G. Busby, Jr., CPA, is a state and local tax attorney at The Cavanagh Law Firm. Busby previously worked in the SALT departments at Arthur Andersen and Deloitte & Touche. Before entering private practice, Busby was in charge of all transaction privilege (sales) tax audits at the Arizona Department of Revenue.

If you have any questions, please contact the author. He can be reached at (602) 322-4146 or JBusby@CavanaghLaw.com.

OCTOBER 2019 AZ CPA

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6. neat animals, horses, asses, sheep, ratites, swine or goats used or to be used as breeding or production stock, including sales of breedings or ownership shares in such animals used for breeding or production; 7. nonmetalliferous mined minerals sold at retail; 8. works of fine art sold at an art auction or gallery in the state to nonresidents of the state for use outside the state if the vendor ships or delivers the item to an out-of-state destination; 9. motor vehicles sold to nonresidents if the purchaser’s state of residence does not allow a use tax exemption corresponding to Arizona’s sales tax and if the nonresident has secured a special 90-day nonresident registration permit for the vehicle — except tax does not apply if the purchaser takes possession of the vehicle outside the state; and 10. motor vehicles sold to enrolled members of Indian tribes who reside on the Indian reservation established for their tribe, unless possession of the vehicle is received on the enrolled members’ Indian reservation.

Tax Trap Could Be Resolved The optional municipal-only sales and use tax exemption for proceeds from sales of paintings, sculptures or similar works of fine art sold by the original artist is included in the retail statute. However, the Arizona Legislature included all of the options for municipalities to tax items not taxed by the state in a separate statute and made no references to these options in the retail statute.

Lawmakers easily could resolve this trap for the unwary during the next legislative session by simply adding a provision in the retail statute that cross-references the statute that adds all of the options for municipalities to tax items not taxed by the state, or by moving those provisions into the retail statute. n

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Dancing With the Choice Many CPAs face a choice in making a tough career decision. Maybe being a CPA was not their first choice or passion. Martin Gaxiola, CPA, faced an unusual choice early on in his career – to be an accountant or to become a Flamenco dancer? And he managed to do both.

Gaxiola went to ASU and majored in accounting. He was always interested in the arts and performed percussion and sang in the Phoenix Boys Choir. While his sisters danced the Flamenco, he never seriously considered trying it until he took a Flamenco/Ballet Folklorico dance class in his junior year at ASU. He fell in love with Flamenco and then was faced with the choice – to continue with accounting or become a Flamenco dancer? He decided to finish his degree in accounting and then took the leap and moved to Madrid after college to become more involved in Flamenco.

He lived in Spain for three years and returned to Arizona where he once again became involved in accounting, working for Phelps Dodge.

After two years at Phelps Dodge, he decided to give Flamenco another try

and went back to Seville, Spain where “everything connected.” He started to take basic classes and studied for another year, returning to the U.S. to dance with the renowned María Benítez Teatro Flamenco company in Santa Fe. Gaxiola toured for five years with the company, traveling all over the U.S., including performing at the prestigious Joyce Theater in New York. Although Gaxiola found Flamenco very rewarding personally, he did not find it very lucrative.

“I loved to dance, but it is hard to make enough money as a Flamenco dancer, so I decided to start thinking about my next step.” His next step was to start and finance his own professional Flamenco company — Callo Flamenco

Ballet de Martin Gaxiola in 2004.

“My accounting experience helped me set up the company as a for-profit and fund it.” He developed and performed in the company for seven years before deciding to return once again to accounting. His most recent jobs included assistant controller at the Cordon Bleu Scottsdale Culinary Institute and accounting manager at the State Bar of Arizona. He obtained his CPA designation this past spring and is also a Certified Fraud Examiner.

Gaxiola now maintains a foot in both the worlds of accounting and Flamenco.

He occasionally performs as a guest artist and can be seen at venues such as the Crescent Ballroom in Phoenix. n – Patty Gannon

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Business Valuation and Forensic & Litigation Services Conferences December 18, 2019 ASCPA Learning Center or Webcast Get up to speed on considerations, methodologies and rulings on a variety of business valuation, forensic accounting and litigation services topics. Attend for a half day focusing on either subject, or stay for a whole day of informative, progressive and dynamic sessions on both subjects from national and local speakers.

Morning Program Forensic & Litigation Services 8 – 11:40 a.m.

Tracing Tips in Forensic Accounting Engagements – A Panel Discussion Moderator: Melissa Loughlin-Sines, CPA, CFE, CVA, CFF Henry+Horne Panelists: Chris Gorman CFE, MAFF Gorman Consulting Group, LLC David S. Cantor, CPA Cantor Forensic Accounting, PLLC Julia A. Miessner, CPA, ABV, CFF, CGMA BeachFleischman PC Lunch Lessons: Breathing Confidence and Power into the Most Valuable Marketing Hour of Your Day Norm Hulcher, Hulcher & Hays, LLC Collaborative Law Process Michael Julifs, MBA, CFP, Fair Share Divorce Jennifer Moshier, Esq., Moshier Law Lost Profits and Interest Rates Rob Mroz, ASA, CBA, CVA, MBA, BDO USA, LLP

Afternoon Program — Business Valuation 12:40 - 4:30 p.m.

Valuations and Family Law — A Panel Discussion Moderator: Melissa E. Loughlin-Sines, CPA, CFE, CVA, CFF, Henry+Horne Panelists: Jeffrey G. Pollitt Jeffrey G. Pollitt, P.C. David Horowitz May, Potenza, Baran, & Gillespie, P.C. Point and Counterpoint Mark R. Hughes, CPA, ABV, CFF Gorman Consulting Group, LLC Brendan J. Kennedy, CPA, ABV, CFF, CVA, ASA, ATLAS CPAs & Advisors PLLC Appraisal Review Speaker TBD A Curmudgeon Looks at the BV Profession Bob Kleeman, CPA, ABV, ASA OnPointe Financial Valuation Group LLC

Networking Power Hour With Bob Kleeman 4:30 – 5:30 p.m.

Learn more at www.ascpa.com/bvfl19 12

AZ CPA OCTOBER 2019

The Future of Fraud in Technology

by Dr. Robert K. Minniti, DBA, CPA, CFE, Cr.FA, CVA, CFF, MAFF, CGMA, PI As we explore the ways that technology can assist us in making us better accountants and auditors, we also need to consider the ways that technology can be used by fraudsters and criminals to take advantage of our businesses and our clients’ operations. Advancing technology can make it easier for criminals to commit fraud. Let’s explore some of the ways that criminals can use technology to advance their nefarious schemes.

With the recent and ransomware attacks on 20 municipalities in the state of Texas, as well as the ransomware attacks on the cities of Baltimore and Atlanta, everyone is aware of the issues with ransomware. Unfortunately, ransomware has become an off-the-shelf franchise fraud scheme. Criminals with little or no computer experience can contact organizations that have written ransomware software through the darknet and license the use of that software. Basically, the new criminals pay an upfront fee to license the ransomware software, and then pay a percentage of the ransoms received as a royalty. Making it extremely easy for anyone to commit this type of fraud.

In today’s world just about everyone has received a letter from an organization they do business with telling them that their personal information may have been compromised in a data breach. Organizations have spent a large amount of money encrypting data to help to ensure that if the data is stolen in a data breach the criminals will not be able to access the information. With current encryption technology it would take several quadrillion years for a desktop computer to decrypt a file that is properly encrypted. Computer scientists estimate that quantum computers, which store data on individual atoms rather than transistors, will be available within the next four to five years. Using a quantum computer, criminals will be able to decrypt the stolen files in a matter of hours. Conversations on the darknet include buying and selling stolen encrypted files, so the criminals can hold

onto those files until quantum computers are available to decrypt them.

Our day-to-day technology with the Internet of Things (IoT) can allow criminals access to our secure systems through various devices connected through Wi-Fi. Consider the items you may have already connected to your system printers, scanners, security cameras, thermostats, motion detectors, doorbells and even the locks on our doors. Many of these devices are connected to our computers, cell phones, and even our servers through Wi-Fi, Bluetooth or the Internet. If we haven’t properly limited access to these devices with encryption technology and access controls, criminals can use the multitude of devices we connected, to gain access to the data on our systems, servers and computers.

Con artists use technology to fool us into giving out personal information or to trusting them. Current technology allows them to create fake IDs and fake identities with background information from free websites readily available on the internet. Criminals used to use photos they misappropriated from various sites on the internet. Now technology allows them to create fake photos that look like the pictures of real human beings to use with their fake identities.

They use these fake identities to set up sites on social networking websites such as Facebook and on online dating sites.

They use the fake identities to contact individuals to gather information about the people and the organizations they work for. They can also use the social networking contacts to transmit malware, viruses, and other harmful software code to both individuals and the companies they work for.

Another type of software available for criminals is known as credential stuffing software. This software allows the criminals to load a multitude of websites, such as banking, financial and employer websites into the software and then use the software to attempt to access those websites. The criminals purchase compromised user IDs and passwords and then use the credential stuffing software to try those user IDs and passwords on

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all the websites they loaded into the software. The criminals are counting on the fact that many individuals use the same user ID and password to access multiple systems. When the software recognizes that has accessed a system, it pauses and indicates that human interaction is necessary to see if there’s anything valuable to steal on the system.

Sometimes we implement new technology in order to help to prevent fraud and in doing so open up opportunities for other types of fraud. One example of this is adding RFID chips to credit and debit cards. This was supposed to make the cards harder to duplicate, and therefore make it harder for the criminals to commit fraud. Unfortunately, RFID stands for radio frequency identification. As you’re aware, you merely have to wave your chip card over a reader

and it will process a transaction on your card for you. Criminals are aware that these chips can be read 3 to 4 feet away from the card. Criminals are using portable point-of-sale devices that send out signals that the RFID chips in the debit and credit cards respond to. This allows the criminal to record a card present transaction for the card it contacted. Criminals take these portable point-of-sale devices to public places such as airports, subway stations, shopping malls, sporting events, etc. and use them to record transactions from unsuspecting victims. Everyone should carry any RFID chip card in RFID safe sleeves or RFID safe wallet.

Criminals have also compromised the charging stations we have grown accustomed to using. They’re placing malware in the charging stations so

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when you are out and about and notice the battery on your mobile device is getting low and you plug into the charging station, they are able to infect your mobile device, and when you connect your mobile device to your computer or server those are also infected.

Criminals are using our communications technology to gain access to our IT systems and data. Everyone’s probably familiar with phishing, which is the use of emails to gather information or infect an electronic device. Criminals have expanded this to vishing, which is done over the phone, for example the call from the Social Security Administration notifying you that your Social Security number has expired and needs to be renewed. Criminals also use smishing, which uses text messages containing links hoping that unsuspecting readers will click on the link or respond to the text message. Criminals also infect pictures and videos they share on social media, so when unsuspecting individuals download the material from the social media website, they infect their devices.

As we continue to automate our workplace, including automated factories and self-driving trucks, the risk of having criminals hack into our systems to disrupt our factories or reroute our trucks is an increasing risk for businesses. There have even been reported cases of criminals hacking into the computers in a passenger car and causing the car to stall or stop in traffic. Imagine the day you get into a self-driving taxi that drives you out to the middle of the desert and demands a huge ransom to bring you back to town. What was once the plot of a science fiction show is becoming more real every day. n Dr. Robert K. Minniti, DBA, CPA, CFE, Cr.FA, CVA, CFF, MAFF, CGMA, PI is a member of the ASCPA and is the President and Owner of Minniti CPA, LLC. He is a frequent speaker for the ASCPA.

Data Analytics Implementation in Accounting Firms

by Virginia Collins Accounting firms are focusing on increasing their usage of data analytics in their audits. This usage will enable auditors to increase the quality of their auditing procedures from the insights that data driven procedures can provide. Auditors will also have the ability to perform data analysis in real time allowing for continuous auditing to be part of their audit strategy.

There is a certain sense of urgency that firms are now feeling to implement data analytics. Businesses are using data analytics to gain a competitive advantage and meet their customers’ expectations. As data analytics becomes part of the everyday business environment, client expectations are that their trusted advisors have also adopted the usage of data analytics in their audit.

Firms recognizing this urgency to implement data analytics have looked first to what tool to purchase as the immediate solution to their data analytical needs. Firms must first realize that purchasing a tool is only one part of what is needed in transforming an audit from traditional auditing procedures to an audit that is driven by data analytics. This article will discuss several areas firms must address in planning for the usage of data analytics in their audit if they are to obtain a successful implementation.

To begin with, firms must realize that the largest barrier they face in implementing data analytics is not having the right skills on their staff. Traditionally, auditors have not aquired the education and experience needed to use data analytics. The mutiple skills needed can include the following disciplines: accounting and auditing, data modeling, programming, and analytical skills to interpret the results and design the data-driven procedures. These skills are usually not found in one person, so firms must come up with a strategy on how these skills can be acquired and used on an as-needed basis to drive the project forward. The strategy firms can consider include: training for staff, using outside consultants on a project basis, and using more experienced auditors who can interpret the results with their knowledge of the industry they currently serve.

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•

Firms will be wise to involve both their IT staff and the client’s IT staff to establish the security controls needed to gain the clients confidence on the auditor’s usage of their data.

Firms must also recognize that implementing a data driven audit is a transformational process. This requires the reengineering of traditional auditing procedures to that of data driven procedures. During this process, traditional procedures will be replaced with data-driven procedures. This reengineering of processes is critical to the firm if they are to maximize the value from a data driven audit.

For example, sampling most likely will become obsolete as data driven procedures allow for all transactions to be subject to the test. Staffing resources of the firm must be realigned during this transition, as technology will perform tasks normally performed by less experienced staff.

How and where data is stored should also be considered by firms. Of utmost importance is the security of the firm’s clients’ data that will be stored.

Firms will be wise to involve both their IT staff and the clients’ IT staff to establish the security controls needed to gain the clients’ confidence on the auditor’s usage of their data. Datadriven procedures will require more data to be stored than was generally used and stored under traditional auditing procedures. A best practice to consider is to establish a centralized server managed by the data analytics development team. This centralization of data will allow for development of data driven procedures, including testing and maintenance of these

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procedures, the necessary controls can be established to verify the accuracy and completeness of the client data, and audit logs and documentation of tests can be maintained to meet current auditing standards requirements.

Development of audit tests should be prioritized based on the common audit objectives that are most important to the firm and take into consideration their available resources. Data analytics can be developed in phases, and the best practice is to start small and gain quick wins. These quick wins enable the firm to see progress in data analytical development and help to gain momentum for further implementation initiatives. Firms should keep in mind that not all auditors need to acquire every skill that is needed for data analytics to be successful. Data driven procedures can be developed by a specialist and then made available to the accounting generalist.

In considering the tool a firm should purchase, it should be clear by now that there is no benefit in purchasing a tool that no one at the firm knows how to use. Firms should establish some criteria before making a major investment in a data analytical tool. Some of the criteria I would recommend using to evaluate a tool are as follows: • Data Sources — How many data sources can it connect to?

• Data Transformation — Does the tool clean up data in a format to allow analysis?

Data Storage — How much data can be stored by the tool and where is the data stored?

• Data Modeling — Does the tool have data modeling capabilities?

• Development of Tests — Does the tool allow for the firm to develop their own tests or are they limited to tests provided by the vendor?

• Documentation — Does the tool provide documentation needed for auditing standards?

• Provider — What is the provider spending for future development of the project, and does it have resources for future development?

• Skills — Do I have the current skills today to implement the tool, is training or are outside resources needed to implement?

• Visualization — What are the visualization capabilities of the tool?

• Cost of Tool — Is the cost prohibitive for the firm?

I have chosen to work with the Power BI suite in my data analytical consulting projects. The Power BI suite was developed by Microsoft for excel analysts to implement a self-service business intelligence solution. When I went through the 10 criteria above, the Power BI suite met all the criteria for my usage requirements. This tool aligns well with accountants who do have excel skills and therefore has the capability of being a total data driven solution for most small to mid-size firms.

In conclusion, firms need to gain momentum in implementing data analytics in their audits to meet the expectations of their clients today. Focusing only on what tool to purchase will not ensure a successful implementation of a data driven audit. What is needed is a holistic implementation plan that includes the considerations mentioned in this article. n Virginia Collins, CPA (in TX,NY,NJ), CITP, CFE, is a consultant for small businesses and CPA firms in managing and developing data initiatives. She has more than 35 years of public accounting experience with the last 10 as a quality reviewer.

The Art of Gaming: What Our Internal Controls Fail to Catch

by Marianne M. Jennings Following a speech at a major university, I submitted, as agreed, my travel expenses. However, no matter what I submitted, the head of the university's travel reimbursement office was not satisfied.

My airfare was the problem. I submitted the bill from my American Express account showing the charge for the ticket, as well as the fact that the ticket had been used for travel to the city where the university was located. The claim for reimbursement was rejected.

So I submitted the receipt from the airline that showed how much I had paid, what the ticket was for, where the ticket took me, and whether the ticket was used. Still, the response was "insufficient proof." The university’s travel office had imposed a robotic type of rule: all airfare reimbursements required the traveler to submit the e-mail the airline sends to passengers upon their finalizing and paying for their reservation and ticket.

Upon reflection, mostly born of frustration for the reimbursement roadblocks, an epiphany emerged. The email from the airline shows that a ticket has been purchased, where the ticket will take the traveler, and how much the traveler paid for the ticket.

But, the email does not show whether the traveler has actually traveled. The email will

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not show whether the traveler canceled that reservation and then booked a less expensive one. The traveler could simply submit the more expensive ticket for reimbursement but actually use the cheaper one. The post-travel receipt was actually superior because it showed the amount paid and whether the ticket was used. The travel office did not have the best evidence, as we say in court.

The best evidence rule exists as a path to truth. So it is with internal controls.

In the pursuit of internal controls, the travel office policy on receipts missed a fairly large loophole. The loophole in controls was that the documentation they were requiring was not actually proof of travel or actual cost. Because of the documentation requirements, and rather ironically, the university gave travelers a way to game the system. As a center director, I had several speakers submit requests for airfare reimbursement for amounts that were

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extraordinarily high. Upon further exploration and documentation requests, we discovered that the ticket submitted was not actually the ticket used. This behavior came from folks who had traveled to speak or participate in panels at our ethics center.

What we have is a volatile combination: the limitless capacity of humans to game numbers and systems and a lack of logic and reasoning in developing internal controls. That volatile combination means fraud. Sometimes in pursuit of the matrix established in the Internal Control-Integrated Framework from the Committee of Sponsoring Organizations of the Treadway Commission (COSO), we may not be thinking through the simplest issues that result in loopholes and losses.

The Wells Fargo Fake Accounts The report on nearly two decades of employees gaming the new-account

set-up system in order to meet their quarterly numbers for new, albeit fake, accounts and account services provides a plethora of ways we can do a better job on internal controls: • Many of the fake accounts were set up by the same bank employee: noname@wellsfargo. com. “No name” did not exist, and the odd appellation was either not a red flag or, as the report noted, there was a failure to follow up with new account holders to verify the claimed creations of employees.

• Wells Fargo’s number of products per customer was 2.5 times the industry average. Questioning phenomenal performance is an internal control tool.

• The number of reports coming into both HR and through the ethics reporting lines was increasing steadily. Those reports

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provided a road map, but the coordination among these areas and audit and risk was not as routine or detailed as it needed to be.

The autonomy of the retail banking portion of Wells Fargo was a type of blockade when other banking divisions raised questions about what they were hearing and about the level of performance.

The Epstein Money-Laundering Following up on the Wells Fargo issue is the case of Jeffrey Epstein, the late and wealthy jet-setter who had been charged with sex trafficking after state child sexual abuse charges resulted in his registration as a sex offender. His relationship with Deutsche Bank is a study in the risks of ignoring what is perhaps one of the most critical components of internal controls — the human element. The complex structures for internal controls serve to reduce to a minimum reliance on the reliability and vulnerability of the human element.

However, there is one human resource that trumps virtually all other forms of internal controls: When employees raise questions and concerns, listen.

Jeffrey Epstein had used JPMorgan Chase as his primary banker, but that bank severed ties in 2013, partially based on reputational concerns. At that point Deutsche Bank became Epstein’s primary banker. Employees raised concerns about Epstein, concerns that escalated when questions were raised in 2018 about his original plea bargain in Florida for the child sexual abuse charges. Those concerns were not heeded. It was not until June 2019 that Deutsche Bank began to sever its ties with Epstein. Deutsche Bank had just settled a criminal case with the United States on other matters by agreeing to pay a $3 billion fine.

The employees were trying to be proactive, particularly in light of the charges and scrutiny the bank was facing. Unfortunately, their warnings, albeit valid, were ignored.

The Samsung America Embezzlement: The Tricky Company Name John Y. Lee managed to embezzle $1.7 million from Samsung America by creating a fictitious entity: Engelhard Supple. Note the spelling error, and another important issue was that the real vendor was Engelhard Corp. Yet Samsung paid the false invoices without questioning the different name, different addresses, or verification that the services noted on the invoices were actually performed. Lee was sentenced to 75 months, ordered to repay Samsung, and had separate issues with the IRS for the failure to pay taxes on his ill-gotten payments. Like the airline receipt vs. the email confirmation, loopholes can be born of a faulty process for verifying payees and checking the consistency of payment accounts or locations.

The President and CFO of the Payroll Services Company Who Never Paid Clients' Payroll Taxes Despite having names straight from central casting, Jerry Wayne Overcash and John Bernard Thigpen are real people, and they founded a real company, CenterCede Services Inc., to provide payroll services for clients. They were sentenced to 21 months in prison for embezzling $2 million by simply not paying clients' payroll taxes. The clients never had verification of payment except the word of Overcash and Thigpen. Reliance on the assurance, “Yes, I did that,” is a loosey-goosey internal control.

The Inmate/Tax Return Preparer This case of fraud gives new meaning to the phrase, “Idle hands are the devil’s workshop.” Whilst in prison in Tennessee for other crimes, Larry Steven Covington Jr. learned from another inmate how to prepare and file fraudulent tax returns. When prison reformists speak of the need for inmates to learn new skills in prison, this instruction is not on the list of skills to develop.

With his training and certification in hand, Covington stole the identities of his fellow inmates. Covington then fed

his fellow inmates’ information to his mother (in letters and by phone calls).

Mom Covington used the information to fill out and then file tax returns for the unwitting inmates. Interestingly, all of the 550 tax returns filed resulted in refunds. Those refund checks were then either deposited directly into two bank accounts that Mom Covington had set up or were sent directly to Mom Covington’s house. Covington instructed his mother to keep a little of the refunds for herself, and then purchase Green Dot cards for Covington with the rest. Green Bank issues prepaid debit cards known as Green Dot cards. Mom Covington is now doing time as well. No word on the types of skills she is learning there.

Perhaps the most interesting aspect of the case is that the IRS is the organization with internal controls issues. The singular address and same two bank accounts for the refunds could have been caught in the simplest of crosschecking programs. For example, retail pharmacy companies have flags built into their systems for prescriptions that are filled for different patients who all have the same address. The computers flag prescriptions to singular addresses, a means by which retail pharmacy companies establish sufficient controls on their distribution of prescriptions for federal compliance standards. The simplest cross-checks tools on disbursements are key, but often missing, internal controls.

The number of these cases in which financial crimes are committed is increasing despite extraordinary efforts to tighten up internal controls. In the pursuit of the flow charts and processes, we seem to forget the airline ticket principle: Just because you have a receipt does not mean the ticket was used.

We can add more basics from these cases: • Just because they said they paid does not mean they paid.

• Just because the company name looks familiar does not mean you are paying the right vendor.

• Just because electronic payments seem efficient does not mean the mechanisms have controls.

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Governmental Accounting Conference Feb. 5, 2020

Desert Willow Conference Center - 8–4:30 p.m.

4:30 – 5:30 p.m. Networking Available In-Person or via Webcast Recommended CPE Credit: 8 hours Hear the latest on GASB; learn more about change management, fraud detection and cybersecurity; and participate in cyber warfare bootcamp at the 2020 ASCPA Governmental Accounting Conference. Your favorite speakers, including David Cotton, Marianne Jennings and David Bean, are back, along with other local and national experts to assist you in discovering insights and understanding on new developments in governmental accounting and auditing.

Special thanks to Platinum Sponsor — Henry+Horne.

Learn more at www.ascpa.com/gac20

ax Guide Arizona T

r ger, Partne Pat Derden Rodis, CPA Stephen J. lars, CPA Zol Edward K.

by the Published ty of CPAs Arizona Socie Workshop Phoenix Tax

Order the only comprehensive guide on Arizona taxes.

Authors: Pat Derdenger, Steve Rodis and Ed Zollars

New in the 2020 Arizona Tax Guide:

• Details of Arizona law changes to reflect conformity with changes made in the 2017 Tax Cuts and Jobs Act • MRRA changes to the alteration limitations and exclusion of contractors not required to be licensed by the Registrar of Contractors from the prime contracting classification • Option to bypass OAH and appeal directly to the state board of tax appeals or the tax court • Required registration with the DOR for online lodging marketplaces

The Arizona Tax Guide includes the following guides: • The Arizona Income Tax Guide • The Arizona Sales and Use Tax Guide • The Arizona Personal Property Tax Guide • The Arizona Unclaimed Property Guide

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The diabolical logic of thinking through how cash could be diverted is the key to solid internal controls. Think through what the human imagination could concoct to be sure it never happens. n Marianne Jennings is a professor emeritus of legal and ethical studies in business in the W.P. Carey School of Business at Arizona State University. She will be presenting at the Arizona Federal Tax Institute Conference on Nov. 8 and the Governmental Accounting Conference on Feb. 5, 2020. (This article is updated from an article that appeared in Accounting and Compliance Alert on March 13, 2017.)

2020 Arizona Tax Guide

2020

Tax Guide ona Income Guide 2020 Ariz & Use Tax de ona Sales ty Tax Gui 2020 Ariz al Proper ty Guide ona Person per Ariz Pro 0 ed 202 Set ona Unclaim 4-Volume 2020 Ariz

•

Check addresses and sheer numbers of payments.

Just because you want to trust does not mean you should trust.

Just listen when employees express concerns.

Order online and learn more about the guides at www.ascpa.com/taxguide2020 AZ CPA OCTOBER 2019

Spiral-Bound Book: Pre-Order by Dec. 16, 2019 Members of ASCPA, Phoenix Tax Workshop, State Bar of Arizona or Enrolled Agents: $85; Nonmembers: $105 After Dec. 16, 2019 Members of ASCPA, Phoenix Tax Workshop, State Bar of Arizona or Enrolled Agents: $95; Nonmembers: $115 Electronic PDF: Members of ASCPA, Phoenix Tax Workshop, State Bar of Arizona or Enrolled Agents: $79 ; Nonmembers: $99

Guides will be available for delivery mid-January 2020.

AZ CPA Quick Quiz You’ve Read It, Now Get Credit Take this quiz on AZ CPA content online or submit this hard copy.

Receive a score of 70 percent or more and earn one hour of CPE credit in specialized knowledge. It’s that easy!

Fees: Members: $25 Nonmembers: $40 Online Access Go to www.ascpa.com/quickquiz to access links to all active quizzes. Once a quiz is purchased, a link and password will be emailed to you. Your results will be sent immediately after completion, and certificates are emailed within two business days.

Hard Copy Please select one answer for each question. Fill out registration/payment information below and mail or fax to the Society office. Quiz results and certificates will be emailed to the address provided on the registration form. *This quiz will be available until October 2020. Please note that users have three attempts to pass the quiz with at least a 70 percent score.

October 2019 Issue of AZ CPA* 1. In this month’s Chair’s message, Van Arsdale talks about: m How technology can make your life easier m How technological disruptions could impact your practice m His latest laptop purchase

5. What was once the plot of a science fiction show may now become a real threat? m AI devices taking over the IRS m Hijacked driver-less cars kidnapping people for ransom m AI taking over accounting jobs

2. In Wayfair, Lawmakers permitted municipalities an option to impose sales and use taxes on up to 10 categories of items that the state exempts, including: m Works of fine art sold at an art auction or gallery in the state to nonresidents of the state m Textbooks required by any state university/community college sold by bookstores m All of the above

6. The largest barrier a firm faces in implementing data analytics is not having the right skilled staff. m True m False

7. Collins recommends the following data analytic tool: m Power BI suite m Google Analytics m Data Done Right 8. Who managed to embezzle $1.7 million from Samsung America by creating a fictitious entity: m Bernie Madoff m John Y. Lee m Calvin Broadus, Jr. 9. In the case of Jeffrey Epstein, what should have been done to stop his money laundering scheme? m His past taxes should have been reviewed m Employee whistle-blowers should have been heeded m His money should have been examined 10. CenterCede Services Inc. was a payroll company that did not: m Pay its clients’ payroll taxes m Get indicted for fraud m Pay any penalties

Quick Quiz Registration Name: ____________________________________________________ Email:_____________________________________________________ Telephone: _________________________________________________

3. ASCPA member Martin Gaxiola also had a career as a: m Race Car Driver m Instagram Influencer m Flamenco Dancer 4. In Bob Minniti’s article, smishing is: m When thieves use text messages containing links m When phishing goes awry m When your chip reader is damaged

Payment

m Member: $25 m Nonmember: $40 Checks: Please make payable to: The Arizona Society of CPAs Credit Card:

m Visa m MasterCard m American Express

Credit Card #: _______________________________________________ Expiration Date: _____________________________________________ Name on Card. _____________________________________________ Mail to: ASCPA, 4801 E. Washington St. Suite 180, Phoenix, AZ 85034-2040; fax to (602) 252-1511 scan and send to ASCPACPE@ascpa.com.

OCTOBER 2019 AZ CPA

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Classifieds Business Opportunities ACCOUNTING BIZ BROKERS — Ready to Sell Your Firm? Selling your firm is complex. We can make it easy!

ACCOUNTING BIZ BROKERS has been assisting firm owners sell and transition their firms for 15 years and we can help you! Contact Kathy Brents, CPA CBI at (866) 260-2793. Website: http://www. accountingbizbrokers.com.

SEEK CPA TO SELL CPA PRACTICES — Continue your present practice while learning this unique and prestigious service. Full training and support. Member of Arizona Society of CPA a must.

Contact us today! hankins@ableta.com or phone (817) 738 3287.

BOOKKEEPING FIRM LOOKING TO ACQUIRE BOOKKEEPING CLIENTS —Tucson bookkeeping firm is looking to acquire bookkeeping clients.

Please contact Lance at (520) 245-0372 or by email at lance@bookkeepingtucson. com.

Employment TAX PREPARER — NORTH SCOTTSDALE CPA FIRM — is seeking a parttime (retired) Senior Tax reviewer during peak season. Must have seasoned tax review experience with updated knowledge of tax law and paperless systems. Larry@partridgecpas.com.

ASSISTANT CONTROLLER FOR LOCAL CONSTRUCTION CONTRACTOR — Full-time assistant controller, direct report to CFO, at successful local construction contractor.

Financial, accounting, and administrative support functions for construction contracts receivable, accounts payable, payroll, and month-end for several entities. Interact with banks, insurance brokers and agents, general contractors, vendors, CPAs. $60-80,000...DOE +Benefits. Applicant should have Bachelor’s Degree, 5+ years of accounting experience, knowledge of GAAP, strong Excel and analytical skills, knowledge of the Percentage of Completion method

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AZ CPA OCTOBER 2019

of accounting. Timberline experience preferred. CPA or CMA preferred. Email resume to ConstructionControllerPHX@ gmail.com.

AUDIT SENIOR / MANAGERS — Deloitte — Are you passionate about numbers and data analysis with a keen interest in the details? Do you want a daily collaborative environment, thinktank feel and the ability to share new ideas with your colleagues - without the extensive demands of travel? If so, consider an opportunity with our Phoenix/ Gilbert U.S. Delivery Center. Working independently as well as collaborating with diverse group of talented audit & assurance professionals, you will be exposed to our clients to understand their business, the risks they face, their accounting processes and their internal controls. Learn more about the Deloitte U.S. Delivery Center - https://usrecruiting.deloitte.com/deloitte-usdc-west.

SENIOR TAX MANAGER ~ TAX MANAGER ~ TAX STAFF OPPORTUNITIES — REDW — One of the Southwest’s 10 largest accounting and business consulting firms, has opportunities for talented tax professionals at all levels for our growing practice. With offices in Phoenix and Albuquerque, we have been serving our clients for more than 60 years. REDW provides tax and accounting services to family owned businesses, closely held and multi-state companies, trusts and estates, and individuals. Ready to take your career to the next level and join an organization with an impressive culture, benefits and compensation package? Learn more at www.redw.com/careers.

SENIOR ACCOUNTANT — CPA (6090K) — Annexus is a well-established, highly profitable, dynamic, fast-paced, hyper growth company in North Scottsdale. We have a unique opportunity for a CPA to join our collaborative, high performing accounting team. Qualifications: Highly intelligent; Effective communicator; Ability to work within a team, managing up and down; Solid understanding of complex debt and

equity transactions; Experience with Public Company Audits, and S Corp Consolidated Tax Returns; Knowledge of 2017 Tax Cuts and Jobs Act and ability to implement new standards; Ability to learn software programs quickly; Must be a licensed CPA with 2-5 years experience. http://www.annexus.com.

ALEXANDRA L MILLER CPA PC — Full-time tax preparer needed for a small and friendly Tucson CPA firm.

Candidate must have five years of experience in both income tax preparation and accounting/bookkeeping. Candidate must also possess outstanding customer service skills and be able to handle multiple projects at once. Salary DOE. Come grow with us! — Alex@ alexmiller-cpa.com.

Office Space OFFICE SPACE IN CENTRAL PHOENIX (16th Street corridor). Recently renovated office space approx. 1,150 SF with separate entrance opening into courtyard available in premier professional location with great visibility.

Access to breakroom & conf room.

Call Jason at (602) 850-5110, or email jason@azcre.biz .

16TH STREET & GLENDALEJUST OFF FWY. 160 and 215 sq ft in shared space with CPAs in single story professional bldg. Ideal for CPA, Atty, Financial. Ample parking & access to large conf room, breakroom, and office services. Great rate. ira@felco.biz. (602) 850-5101.

EXECUTIVE OFFICE SPACE FOR LEASE — Beautiful garden-style office complex in a great environment in north Phoenix. Easy access to SR 51 and SR 101; near Tatum and Shea. Executive office $800, interior office $650. Ample parking, beautiful conference rooms and seminar room. Copier, telephone, internet ready. Includes Receptionist to greet clients. Contact Julie (602) 953-5000.

Arizona Federal Tax Institute Conference Nov. 7-8 Desert Willow Conference Center 8 a.m. to 4:30 p.m.

Now Also Offered as a Webcast

Get the most up-to-date information on this year’s biggest tax topics.

Day 1 Arizona and Phoenix Metro Economic Update Jim Rounds, Rounds Consulting Rounds will provide a national and state economic overview, including what the numbers are telling us and how public policy can impact performance.

Foreign Investment – U.S. Tax Guide for Foreign Investors Burgess Raby, Raby Law Office Get a step-by-step analysis of the tax issues and forms that may be encountered when the client is a foreign investor. Topics to be addressed will include determining when a person is a foreign person for U.S. tax purposes, the effect of treaties on the taxation and reporting of foreign investors, determining when a U.S. trade or business may be conducted, tax-advantaged alternatives to direct investment, effects of a foreign investor investing in a U.S. limited liability company, and complying with U.S. withholding requirements.

State Taxation of Trust Income and Trust Overview James McGettigan, Stoker Ostler Wealth Advisors Get an interactive overview of trusts, focused on the tax attributes of common trusts used in multigenerational planning. Understand the influence beneficiaries, trustees, and settlors have on trust income taxation. Receive an overview of key nuggets on recent state trust taxation updates and from two recent court cases: the SCOTUS decision in North Carolina vs. Kaestner and Minnesota’s Supreme Court ruling in Fielding vs. Commissioner of Revenue.

Section 199A: Applications and Challenges Phil Jelsma, Crosbie Gliner Schiffman Southard & Swanson LLP Code Section 199A, the 20% pass-through deduction is one of the biggest changes included in the 2017 Tax Act. This program will discuss the legislative background of Code Section 199A, as well as the IRS’ proposed and final regulations.

We will emphasize the planning opportunities presented in the final regulations, with a focus on the aggregation and specified service trade or business rules.

Federal Taxation of a Cannabis Business Melissa Harrington, Price Kong Co. CPAs P.A. A marijuana business, regardless of state law, is considered to be operating an illegal activity under federal law.

Accordingly, there are numerous nuances and complications related to taxation of marijuana businesses at a federal level, starting with Code Section 280E, which disallows many expenses of these businesses. This presentation discusses the various methodologies applied to marijuana businesses to limit the federal tax burden and deal with the IRS. Arizona Finally Jumps on the Wayfair Bandwagon Pat Derdenger, Lewis Roca Rothgerber Christie LLP Arizona finally jumps on the Wayfair bandwagon and adopts economic nexus for e-commerce sales and preempts the retail classification for city tax. Arizona H.B. 2757 adopts economic nexus standards effective Oct. 1, 2019 for internet sales made in Arizona in response to the U.S. Supreme Court’s decision in South Dakota v. Wayfair, 138 S. Ct. 2080 (2018). H.B. 2757 also requires marketplace facilitators (Amazon, et. al.) to collect the sales tax on behalf of sellers using the facilitator’s platform and requires the cities to use the state retail classification rather than the Model City Tax Code.

Day 2 The Ethical Lapses of 2018-2019 and Their Lessons Marianne Jennings, Arizona State University Parents made contributions to charities that then funneled the money to coaches who then got the parents’ kids into Tier-One universities as special-admit athletes. Equifax had a major security breach, but had ignored warnings, and managers dumped their stock before the truth emerged.

McKinsey & Co. had to settle with the Feds for its failure to disclose its interests in the parties in Chapter 11 bankruptcy, even as it negotiated repayment and restructuring deals. In each lapse, there are lessons for all of us — how the bright, capable, and successful people lost their ways and how we can learn to catch ourselves before heading off the ethical and legal cliff.

Retirement Impact of the SECURE Act Lisa Germano, Actuarial Benefits & Design Company This session will highlight the provisions of the Secure

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Act and showcase the impact they may have for retirement plans. There is much legislative history in the development for this legislation. Germana will develop the broad picture of why some of these changes were needed, some more complicated than they could be, and where some will change the future for retirement plans. *If the Secure Act has not passed at the time of the conference, our presenter will share her expertise on an alternate retirement planning topic.

Penalty Games: Reducing IRS Penalties Bob McKenzie, Saul Ewing Arnstein & Lehr LLP Each day the Internal Revenue Service asserts millions of dollars in tax penalties against taxpayers. Many of those penalties are subsequently abated because of quality representation by experienced practitioners. This presentation will cover the basics of supporting reduction of IRS tax penalties. You will learn about reasonable cause, ordinary business care and prudence, Internal Revenue Service preferred reasons for abatement of penalties and a practical approach to seeking abatement of penalties. After this session, you should be able to substantially reduce many tax penalties asserted by the Internal Revenue Service against your clients.

Practical IT Practices for Tax Firms Tim Klein, TAK Technology LLC “Don’t let perfect be the enemy of the good.” During this high-level discussion, we’ll outline some of the tasks and management practices everyone needs and offer simple, practical ways to make your IT environment function better and improve security. I will simplify terms like Encryption and Two Factor Authentication, making them easier to understand and implement.

I will also share some best practices and small changes that can have a significant impact on your security and productivity.

Tax Developments in 2019 — What’s New Edward K. Zollars, Thomas, Zollars & Lynch, Ltd. This session will discuss the changes found in the Taxpayer First Act and any other legislation Congress may have enacted by the conference. As well, we will review the regulations and other guidance issued by the IRS in its continued implementation of the changes in the Tax Cuts and Jobs Act, along with other cases, rulings and developments impacting taxes that have taken place in 2019.

Learn more at www.ascpa.com/tic19

Don Farmer Tax Update Oct. 25 Scottsdale Resort at McCormick Ranch or webcast It’s time to review the countless tax developments for 2019 Don Farmer’s 2019 Tax Update will get you ready for year-end planning and for the 2020 tax season. Let Farmer bring you up to speed on all the latest developments for 2019. Due to major tax changes under the Tax Cuts and Jobs Act (TCJA), the 2019 tax season was one of the most challenging tax seasons in recent memory. But the challenges under TCJA did not end with the 2018 tax year. The final §199A regs are mandatory beginning in 2019, and IRS continues to issue significant guidance on many of TCJA’s key provisions.

www.ascpa.com/donfarmer19 24

AZ CPA OCTOBER 2019

Get Up-to-Date With Our Latest Tax Courses

Arizona Federal Tax Institute Conference Nov. 7-8 Thank you to Gold Sponsors: Catholic Charities Community Services Institute for Better Education Catholic Education Arizona

Learn more at www.ascpa.com/tic19

Don Farmer’s Tax Update Oct. 25 www.ascpa.com/donfarmer19

OCTOBER 2019 AZ CPA

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PRSRT STD U.S. Postage PAID Phoenix, Arizona Permit No. 952

Arizona Society of CPAs 4801 E. Washington St., Suite 180 Phoenix, AZ 85034-2040

ADDRESS SERVICE REQUESTED

WHEN A BABY CRIES FOR METH INSTEAD OF MILK.

TAX DOLLARS CAN SAVE LIVES. Abuse and neglect are all too real in Arizona. But this tax season, you can help by encouraging your clients to take advantage of the Arizona Income Tax Credit for Qualifying Foster Care Charitable Organizations.

YOUR CLIENTS CAN SAVE UP TO $1,000. HERE’S HOW: 1. DONATE at GenJustice.org/donate/tax-credit 2. CLAIM the tax credit on Form 352 with GenJustice Qualifying Number 10053

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AZ CPA OCTOBER 2019

JUSTICE CAN’T WAIT genjustice.org