Federal Tax Update
February 18, 2014
Jeffrey D. Frank
Deloitte Tax LLP
Indianapolis, IN
(317) 656-6921
jdfrank@deloitte.com
Kristina Rasmussen
Deloitte Tax LLP
Minneapolis, MN
(612) 397-4178
krasmussen@deloitte.com
Jeffrey D. Frank
Jeff leads both the nonprofit and employee benefits practices for the
Indianapolis office of Deloitte Tax LLP. He has over 26 years
experience serving non-profit institutions including hospitals, health
systems, foundations, colleges and universities, trade associations,
and student loan organizations. Jeff consults regularly with non-profit
organizations on a variety of tax and compensation matters including
unrelated business income tax issues, structuring joint ventures and
similar transactions, tax-favored retirement programs, executive
compensation matters, employment taxes and fringe benefits, and
representing non-profit organizations during IRS examinations.
Jeff earned his BS in Accounting at Indiana University and an MS in
Taxation at Drexel University. Jeff is the immediate past chair of the
AICPA Exempt Organizations Tax Technical Resource Panel and serves
on the AICPA Non-Profit Organizations Conference Steering
Committee. He is also an emeritus member of the IRS Employee Plans
TE/GE Council for the Great Lakes Region and serves on the Board of
Directors and Finance Committee at Dress for Success Indianapolis.
2
Kristina A. Rasmussen
Kristina is a senior manager in the Minneapolis office of Deloitte Tax, LLP. Kristina
has more than 15 years of experience working with not-for-profit clients, including
public and private foundations, health care organizations, higher education
institutions, and other public charities as well as related taxable entities. She has
assisted a diverse group of clients working on a variety of issues related to the notfor-profit industry, including unrelated business income issues, tax-exempt status
qualifications, IRS Coordinated Examination Program (CEP) audit issues, and tax risk
assessments. Kristina recently spent three years supporting Deloitte’s Washington
National Tax Practice as a specialist in tax matters related to tax-exempt
organizations.
Kristina received her bachelor’s degree from the University of St. Thomas and her
M.B.A. from the University of St. Thomas. She is an associate member of the
American Institute of Certified Public Accountants Tax-Exempt Organizations Tax
Technical Resource Panel. Kristina has spoken on tax-exempt matters at conferences
including the American Institute of Certified Public Accountants, the National
Association of College and University Business Officers, and the Central Association of
College and University Business Officers.
3
Agenda
•
•
•
•
•
•
•
•
4
Treasury-IRS Priority Guidance 2013-2014
2013 ACT report
IRS Initiatives and Updates
Legislative Activities
Regulatory Update
Rulings and Cases of Note
IRS Information
Concluding Comments
Treasury-IRS 2013-2014 Priority Guidance
• Exempt Organizations:
• Revenue Procedures updating grantor and contributor reliance criteria
under IRC §170 and §509.
• Revenue Procedure to update Revenue Procedure 2011-33 for EO Select
Check.
• Guidance under §501(c)(4) relating to measurement of an organization's
primary activity and whether it is operated primarily for the promotion of
social welfare, including guidance relating to political campaign
intervention.
• Proposed regulations were issued in November 2013 providing guidance for
tax-exempt social welfare organizations on candidate-related political activities
• Final regulations under §501(r) and §6033 on additional requirements for
charitable hospitals as added by the PPACA. Proposed regulations were
published on June 26, 2012 and April 5, 2013.
• Additional guidance on §509(a)(3) supporting organizations. Final and
temporary regulations were published 12/28/12.
• Notice 2014-4 was issued in January providing interim guidance regarding Type
III organizations supporting a governmental entity
5
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Treasury-IRS 2013-2014 Priority Guidance (cont.)
• Guidance under §4941 regarding a private foundation's investment in a partnership
in which disqualified persons are also partners.
• Final regulations under §4944 on program-related investments. Proposed
regulations were published on April 19, 2012.
• Guidance regarding the new excise taxes on donor advised funds and fund
management as added by §1231 of the Pension Protection Act of 2006.
• Regulations under §6011 and §6071 regarding the return and filing requirements for
the §4959 excise tax for community health needs assessments failures by charitable
hospitals as added by §9007 of the PPACA.
•
Final and temporary regulations were issued in August 2013 regarding the excise tax
• Guidance under §6033 on returns of exempt organizations.
• Final regulations under §6104(c). Proposed regulations were published on March 15,
2011.
• Final regulations under §7611 relating to church tax inquiries and examinations.
Proposed regulations were published on August 5, 2009.
6
Copyright © 2014 Deloitte Development LLC. All rights reserved.
2013 ACT report
2013 Advisory Committee on Tax Exempt and
Governmental Entities (ACT) Report
• IRS’s ACT released annual report on September 12, 2013
• ACT is group of external stakeholders who advise the IRS on
policy and procedural improvements
• Exempt organization report addressed leveraging IRS internal
and external resources regarding:
• Form 990-EZ filing requirements
• IRS customer education and outreach
• IRS information sharing with state charity regulators
8
Copyright © 2014 Deloitte Development LLC. All rights reserved.
IRS Initiatives and Updates
Colleges & Universities Compliance Initiative
• September 2008, 400 questionnaires were sent to public and
private four-year colleges and universities inquiring about
• Unrelated business income
• Endowments
• Executive compensation
• Interim report was published May 2010
• Final report issued April 25, 2013 focusing on:
• UBTI
• 34 were examined as a result of survey responses
• Closed 31 or 34 examinations of schools, overwhelming majority had
adjustments
• Total Adjustments were $90 million
• Disallowed $170 million in NOLs
• Reasons: Improper Expense Allocations and Lack of Profit Motive
10
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Colleges & Universities Compliance Initiative
• Most common UBTI activities
• Fitness, Recreation centers and sports camps
• Advertising
• Facility Rentals
• Arenas, and
• Golf
Other items of note in the Report:
1. Average Total Compensation of ODTKE: $623,267
2. Executive Compensation: About 20% failed to meet rebuttable
presumption due to failure of comparability data to be similarly situated
or have selection criteria documented or specify whether amounts were
salary or other types of compensation.
3. Wage adjustments of $36 million with taxes and penalties of $7 million
11
Copyright © 2014 Deloitte Development LLC. All rights reserved.
IRS Compliance Check Project: IRC Section
457(b) Plans
• 400 questionnaires will be sent in FY13-14 to non-governmental plan
sponsors
• 457(b) plans are sponsored by a state or local government or an
organization exempt under IRC Section 501(c)
• Participation is limited to highly compensation employees or groups of
executives, managers, directors or officers
• Project is designed to:
•
•
•
•
12
Learn more about the operation of non-governmental 457(b) plans
Verify that the plans comply with the IRC requirements
Identify noncompliance issues
Recommend ways to remove any barriers to compliance
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Automatic revocation of exempt status
• Revenue Procedure 2014-11
• Four new procedures to apply for reinstatement of exempt
status after auto revocation
• Streamlined retroactive reinstatement for small organizations
within 15 months of revocation (for 990-EZ or 990-N filers)
• Retroactive reinstatement within 15 months of revocation (for
990 filers)
• Retroactive reinstatement more than 15 months after revocation
• Reinstatement from post-mark date
• Must file Form 1023 application for exemption and
demonstrate reasonable cause for failure to file
• New procedures may apply to applications currently pending
13
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Health FSA
• IRS issued Notice 2013-71 on October 31, 2013
• Allows an employer to amend its flexible health spending
arrangement (Health FSA) to permit an employee to carry a
balance of up to $500 forward to the next plan year
• Carryover does not affect the maximum salary reduction for
the next plan year
• New carryover option is an alternative to the current grace
period rule
• Employers must amend their Section 125 plan documents
accordingly to adopt the carryover option
14
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Foreign reporting
• FBAR
• FinCEN Form 114 (formerly Form TD F 90-22.1)
• Foreign bank account report due annually by June 30
• Form must be e-filed starting July 1, 2013 through the BSA E-File system
• FATCA
• Requires foreign financial institutions to register for global intermediary
identification numbers and to perform 30% withholding on payments to nonU.S. entities that do not certify their compliance with FATCA or disclose their
substantial U.S. owners
• FATCA broadly defines foreign financial institutions to include any foreign
entity that accepts deposits; holds financial assets for the account of others as
a substantial part of its business; or engages primarily in the business of
investing or trading securities, commodities, partnerships or any interests in
such positions
• IRS released a draft Form 8966 “FATCA Report” for foreign financial
institutions and withholding agents to report information on U.S. accounts
• FATCA compliance deadlines start April 2014
15
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Other IRS Activities
Public disclosure requirements
• IRS released FAQs regarding public disclosure requirements for
annual returns and exemption applications
• http://www.irs.gov/Charities-&-Non-Profits/Exempt-OrganizationPublic-Disclosure-and-Availability-Requirements
16
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Legislative Activities
Senate Finance Committee tax reform discussion drafts
• Three reports issued November 20-22, 2013 by Senate Finance Committee
Chairman Max Baucus (D-Mont.)
• Reports include proposed tax reform language and technical explanations
• Tax administration reform
• Simplify tax filing process
• Accelerate due date for partnership income tax returns from April 15
to March 15, delay due date for S corporation returns to March 31,
delay due date for C corporation returns to April 15
• Accelerate deadlines for Forms W-2 and 1099
• Require tax-exempt organizations to file Form 990 electronically
• International tax reform
• Overhaul of the tax rules governing U.S. multinational corporations
• Cost recovery and accounting reform
• Repealing current-law depreciation rules
• Eliminating like-kind exchange rules
• Eliminating last-in, first out method of accounting
18
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Legislative Update
• Patient Protection and Affordable Care Act (ACA) includes many provisions
impacting tax-exempt organizations:
• Medicare tax increase of 0.9% on employee wages in excess of $200,000
effective January 1, 2013
• Report the value of the health insurance coverage you provided to each
employee on W-2
• Transition relief for certain ACA provisions scheduled to be effective in 2014:
• Information reporting of “minimum essential coverage” applicable to
insurers and self-insured employers, effective for 2015, will be due in 2016
• Information reporting of employee’s health coverage for large employers,
effective for 2015, will be due in 2016
• Employer shared responsibility payments will apply starting in 2015
• ACA Fee for Self-Funded Health Plans
• IRC Section 4375 imposes new fee on health care insurance companies and
employers that sponsor self-insured medical plans
• Amount of the fee is based on the “average number of lives covered” under
the plan or policy
• First fee was due July 31, 2013 and is reportable on Form 720
19
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Legislative Update (cont.)
• IRC Sec. 512(b)(13)
• Pension Protection Act provided for an exclusion from UBI for
interest, annuities, rents and royalties received from a controlled
entity if:
• The payments received were less than FMV
• There was a written, binding contract in place as of August 17, 2006
• This exception had been extended through 12/31/2013
• Veterans Work Opportunity Tax Credit Available
• Incentives for employers that hire unemployed veterans as a
credit against payroll taxes
• Notice 2013-14
• Applies to qualified veterans who began work after November
21, 2011 and before January 1, 2014
• Exempt organizations claim the credit on Form 5884-C
20
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Regulatory Update
Proposed guidance for tax-exempt social
welfare organizations
• Proposed regulations issued November 29, 2013
• Guidance on the requirements to qualify as a tax-exempt
social welfare organization under IRC Section 501(c)(4)
• Define the term “candidate related activity,” including:
• Communications that expressly advocate for a political candidate
or party
• Communications within 60 days of a general election
• Certain grants and contributions to political organizations
• Voter registration drives
• Clarifies that the promotion of social welfare would not
include this type of activity
22
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Final tangible property regulations
• Issued on September 13, 2013
• Guidance on application of Section 263(a) to amounts paid to
acquire, produce, or improve tangible property
• Materials and supplies
• Dispositions and general asset accounts
• Effective for tax years beginning on or after January 1, 2014
• Taxpayers permitted to adopt for tax years beginning on or after
January 1, 2012
• Certain safe harbor and de minimis elections are available
23
Copyright © 2014 Deloitte Development LLC. All rights reserved.
501(r) proposed regulations
• IRC Section 501(r) was added to the Code as part of the
Patient Protection and Affordable Care Act enacted March
23, 2010
• IRC Section 501(r) imposes additional requirements for
hospital organizations:
 Community Health Needs Assessment (CHNA) (IRC Section 501(r)(3))
 Must be conducted at least once every three years
 Written report and implementation strategy made available to the public
 Financial Assistance Policy (IRC Section 501(r)(4))
 Limitation on Charges (IRC Section 501(r)(5))
 Billing and Collection Requirements (IRC Section 501(r)(6))
24
Copyright © 2014 Deloitte Development LLC. All rights reserved.
501(r) proposed regulations
• In June 2012, proposed regulations were issued regarding financial
assistance, limitation on charges, and billing and collection
• Prop. Reg. 1.501(r)-4 to 6
• In April 2013, proposed regulations were issued regarding CHNA and
related excise tax and reporting obligations
• Prop. Reg. 1.501(r)-3 and 1.6033-2(a)(2)(ii)(l)
• Prop. Reg. §1.501(r)-3 may be relied upon for any CHNA conducted or
implementation strategy adopted before the date that is six months after
final or temporary regulations are published in the Federal Register
• In August 2013, final and temporary regulations were issued regarding
method and timing for reporting and paying $50,000 excise tax under
Section 4959 for failure to meet CHNA requirements
25
Copyright © 2014 Deloitte Development LLC. All rights reserved.
501(r) proposed regulations
• Notice 2014-2
• Confirms that hospitals may rely on the proposed regulations
pending the publication of final or temporary regulations
• Notice 2014-3
• Contains a proposed revenue procedure that provides correction
and disclosure procedure for certain failures to meet the
requirements of Section 501(r)
• Final or temporary regulations issued for §1.501(r)-1 through
§1.501(r)-6 will be immediately effective
• IRS and Treasury plan to issue final or temporary regulations for both CHNA and
the 2012 regulations at the same time.
26
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Supporting Organizations – Proposed, Temporary and
Final Regulations for Type III Supporting Orgs
• Treasury released regulations 1.509(a)-4 & -4T on December
28, 2012
• Type III - Operated in connection with the publicly supported
organization. Type III SO’s may be “functionally integrated” or
“non functionally integrated”
• Final Regulations Require each Type III supporting
organization to satisfy three criteria as part of that test:
(1) a notification requirement;
(2) a responsiveness test; and
(3) an integral part test.
27
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Supporting Organizations – Proposed, Temporary and
Final Regulations for Type III Supporting Orgs
• Notification requirement for all Type III Supporting Organizations, including parent
organizations and other supporting organizations
• Annual requirement
• Due by the last day of the 5th month after the tax year end of the supporting
organization
• Transition for first tax year ending after December 28, 2012 – notification due the due
date of the supporting organization’s tax return, including extensions
• Can be provided in electronic or paper format
• Type and amount of support provided by the supporting organization to the
supported organization
• Copy of the supporting organization’s most recently filed Form 990
• Schedule B can be redacted
• Copy of governing documents, including amendments
28
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Supporting Organizations – Proposed, Temporary and
Final Regulations for Type III Supporting Orgs
• Two subcategories of Type III supporting organizations: “functionally integrated”
and “non-functionally integrated.”
• “Functionally integrated” Type III supporting organizations are not subject to an
annual distribution requirement
• “Non-functionally integrated” Type III supporting organizations, in contrast, are
subject to an annual distribution requirement
• If not “functionally integrated”, Org must distribute Greater of (1) 85 percent of
the supporting organization’s adjusted net income (as defined in Code Section
4942(f)) for the immediately preceding tax year; or (2) three and a half percent of
the fair market value of all of the supporting organization’s non-exempt-use assets
for the immediately preceding tax year. (Final regulations refer to Temporary
Regulations)
•
29
Notice 2014-4 providers interim guidance for Type III organizations supporting a
governmental entity
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Rulings and Cases of Note
Contributions to SMLLC
• Notice 2012-52
• Provided long-awaited guidance that contributions of assets to a SMLLC
owned by a charitable organization would be treated as a charitable
contribution
• Applies to assets such as real estate and other property commonly housed in a
SMLLC
• Contribution treated as if it was made directly to the charity itself
• INFO 2013-0006
• SMLLC owned by a section 501(a) organization is disregarded for federal tax
purposes and receives the benefits of its owner’s tax-exempt status
• Not required to pay federal tax or file a federal tax or information return, with
the exception of employment returns.
• Describes LLCs’ treatment with regard to employer identification numbers,
transactions that might affect exempt status, organizational documents, and
election to be treated as separate from the owner
31
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Other Rulings of Note
• PLR 201319031
• IRS denies 501(c)(4) exempt status to organization formed to promote
health care reform and conduct research on health care system
• Operated in commercial manner and primarily for benefit of members
rather than community, so not a social welfare organization
• PLR 201331008
• IRS denies exempt status to research organization
• Funded primarily by membership dues. Members received discounts on
nutritional supplements sold by related entity. Organization also
provided “grants” funding research by for-profit entities.
• IRS held that organization operated for non-exempt purpose of
marketing supplements
• PLR201328035
• IRS determines that an organization's interest in a for-profit Scorporation, together with the the flow-through allocation of the entity’s
“S” tax items subject to unrelated business income tax, would have no
effect on tax-exempt status
32
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Other Rulings of Note (cont.)
• PLR 201328020
• Scholarship v. compensation issue
• IRC Section 501(c)(3) organization operates college scholarship program
for middle and high school students who meet certain academic and
community service requirements
• IRS rules that community service aspect does not result in benefit to
grantor organization and scholarship is not compensation for services
rendered under IRC Sec 117(c)
• PLR 201306023
• IRS rules that IRC Section 512(b)(5) capital gains exemption will apply to a
series of proposed sales of condominium interests
• Found that the taxpayer did not hold the property with the primary intent
of selling the property to customers in the ordinary course of a trade or
business; not subject to UBI
33
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Other Rulings of Note (cont.)
• PLR 201251019
• IRS rules that annual read-aloud program directed at children
was a trade or business, was regularly carried on, and was
substantially related to organization’s exempt purpose of
promoting literacy, reading and imagination in children
• Found to be “regularly carried on” even though event only
conducted on weekends during two months prior to Christmas
for a total of 11 days per year
34
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Certain Cases of Note
The Vancouver Clinic, Inc. v. US (2013 )
• Federal District Court in Washington State concluded that
advances paid by a clinic to new physicians constituted
compensation rather than loans at the time of payment despite
the requirement of repayment with interest if they did not
remain at the clinic for five years; the Court concluded that the
parties did not intend repayment and that the requirement
functioned essentially as a liquidated damage provision
• Loan Agreement required 5 year employment
• Over $1.5M was advanced from 2007-2009 with an
overwhelming majority forgiven
35
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Certain Cases of Note (cont.)
U.S. v. Quality Stores, 110 AFTR 2d 2012-5827 (6th Cir. 2012 )
• Court of Appeals for Sixth Circuit held that severance payments
were not subject to FICA taxes
• Case addresses severance payments made to terminated
employees, which were not attributable to rendering of any
particular employment services
• Supreme Court has agreed to review the decision
• Oral arguments were heard on January 14, 2014
• IRS has suspended action on administrative FICA refund claims
within Sixth Circuit
36
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Certain Cases of Note (cont.)
Ramirez v. Commissioner (T.C. Summ. Op. 2013-38)
• Tax Court finds that employee of Univision radio station is an
independent contractor with regard to earnings from off-air
appearances for third party sponsors
• Tax Court analyzed “degree of control” exercised by the
principal over the details of work
• Court cited two university cases regarding “degree of control”:
• Reece v. Commissioner (T.C. Memo. 1992-335) – university
professor also taught corporate seminar classes on his own
time. Professor = employee, seminars = independent
contractor
• Robinson v. Commissioner (T.C. Memo. 2011-99) – vocational
instructor at university who prepared own course materials =
independent contractor
37
Copyright © 2014 Deloitte Development LLC. All rights reserved.
IRS Information
Legal Same-Sex Marriages Recognized for
Federal Tax Purposes
• IRS and Treasury ruled that same-sex couples, legally married
in jurisdictions that recognize their marriages, will be treated
as married for federal tax purposes
• Revenue Ruling 2013-17 issued on August 30, 2013
• Notice 2013-61 issued on September 23, 2013
• FAQs for Registered Domestic Partners and Individuals in Civil
Unions
• http://www.irs.gov/uac/Answers-to-Frequently-Asked-Questionsfor-Registered-Domestic-Partners-and-Individuals-in-Civil-Unions
• FAQs for Individuals of the Same Sex Who Are Married Under
State Law
• http://www.irs.gov/uac/Answers-to-Frequently-Asked-Questionsfor-Same-Sex-Married-Couples
39
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Form 990: 2013 significant changes
• Part IV, Line 2 clarifies that an organization filing Schedule B can limit the contributions
it reports on Schedule B using the greater-than-$5,000/2% threshold only if it checks the
box on Schedule A, Part II, Line 13, 16a or 16b.
• Part VIII, Line 1 clarifies that “contributions” include neither donations of services nor
discounts provided on sales of goods in the ordinary course of business.
• Schedule A clarifies the requirements for functionally integrated and non- functionally
integrated Type III supporting organizations, including the transition rules for how
those organizations can meet the integral part test for tax year 2013.
• Schedule H, Part I, line 7 community benefit table instructions now require that
restricted grants received by the hospital to be used for community benefit must be
reported as direct offsetting revenue in Part I, line 7, column (d).
• Schedule H, Part I instructions clarify that financial assistance does not include self-pay
or prompt pay discounts.
• Schedule J, Part I, Line 4a clarifies that a severance payment includes a payment
pursuant to a separation agreement voluntarily entered into by the parties. (Not just
involuntary separation agreements.)
• Schedule L clarifies that investment management or service fees, but not the value of
investments, are reportable as business transaction amounts in Part IV.
40
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Form 990: 2013 significant changes
• For a full list of changes, refer to the IRS website:
• http://www.irs.gov/Charities-&-Non-Profits/CharitableOrganizations/2013-Form-990-and-990-EZ:-Significant-Changes
41
Copyright © 2014 Deloitte Development LLC. All rights reserved.
IRS Website Links
• Charitable and Nonprofit Entities
• http://www.irs.gov/Charities-&-Non-Profits
• Exempt Organization Newsletter
• http://www.irs.gov/Charities-&-Non-Profits/Current-Edition-ofExempt-Organizations-Update
• Workshops and webinars
• http://www.irs.gov/Charities-&-Non-Profits/Calendar-of-Events
• Government Entities
• http://www.irs.gov/Government-Entities/Federal,-State-&-LocalGovernments
42
Copyright © 2014 Deloitte Development LLC. All rights reserved.
QUESTIONS?
43
About this presentation
This presentation contains general information only and Deloitte is not, by means of this
presentation, rendering accounting, business, financial, investment, legal, tax, or other
professional advice or services. This presentation is not a substitute for such professional
advice or services, nor should it be used as a basis for any decision or action that may affect
your business. Before making any decision or taking any action that may affect your
business, you should consult a qualified professional advisor. Deloitte shall not be
responsible for any loss sustained by any person who relies on this presentation.
44
About Deloitte
Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of
member firms, each of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed description
of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms. Please see www.deloitte.com/us/about for a detailed
description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the
rules and regulations of public accounting.
Copyright © 2014 Deloitte Development LLC. All rights reserved.
Member of Deloitte Touche Tohmatsu Limited
Copyright © 2014 Deloitte Development LLC. All rights reserved.