Standards, policies and procedures assist managers and owners to manage, control, analyze, compare, plan, prepare financial reports and comply with laws and regulations. High standards usually result not only in harm reduction but in increased profits. High standards provide rewards. When we set standards for activities we reduce stress and minimize risk. In the process, we maximize service. Business activities where we set standards, establish policies and procedures include: Records Management and Storage Policy and Procedures Manuals Internal Control Checklists and Evaluation Tools Division of Duties Risk Management Safety in the Workplace – Stop work until it’s safe Building quality relationships Knowing your clients, employees, suppliers and customers and your neighbours Stating and showing you care Invoicing – proud and prompt Handling Money Asset maintenance, repair and security Documentation appropriate to the circumstances Banking Documenting Business Reasons Allocating Business/Personal on purchases Using full AP and AR Accrual Accounting Obtaining rulings re Employee/Self-Employed Ensuring compliance with all regulations/laws, not just tax Maintaining Permanent and Annual files Electronic Records Management Time Management Asset Management Planning, Forecasting and Budgeting Regular scheduled review of books and records with client – monthly, quarterly or annual Consistent, comprehensive working paper files and checklists Identification and affiliation with business and industry organizations Identification and relationship with regulatory authorities Audits by all regulatory authorities © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 1/21 STANDARDS, POLICIES AND PROCEDURES THAT INOCULATE YOU AND YOUR CLIENT AGAINST AN IVI TAX AUDIT: 1. Account for each business, rental or investment property separately, either with a separate general ledger or use jobs, departments or classes to segregate common activities. Use accrual accounting unless cash basis is allowed by the CRA (farming and fishing). 2. Keep all of the records for each client inside or securely stored on top of a banker’s box with a lid attached. Keep the box away from prying eyes. Only work on one client at a time on your desk. If you have to put away one client to work on another, take the time to put away one client and open up another. Do it. Never lose or mix up several clients’ documentation by working on more than one file at once. 3. Sort all of the paper received from a client right away, or ask your client to provide documentation sorted in the following manner: 4. Bank statements by month by account. Credit card statements by month by account. Investment statements including RRSP’s and RRIF’s by month by account. All purchases regardless of payment type, sorted in alphabetical order by supplier name with business reason and customer/job, supplier or other name clearly indicated. Sales invoices by invoice number. This article on Invoicing will provide assistance with how to invoice and how to provide customers with statements. Government reports and correspondence (GST/HST, PST, WCB, Payroll, Tax, etc.). Tax receipts for personal expenses (donations, medical, RRSP, etc.). Put any paperwork not listed above in the “To Do” File for the accountant in the front of the box. Always use the transaction date to post sales, deposits, purchases and payments. GST/HST, Income Tax, PST, Payroll, and WCB all require correct transaction dates. As you post each transaction, file the documentation so if you are interrupted, there is no pile of left over filing. When you start again, you © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 2/21 know exactly what isn’t posted yet because it is not filed away. Here’s what to post and reconcile and in what order: Post all sales first to Accounts Receivable at sale date. Post deposits when received from customer, record in Undeposited Funds. Accumulate and post deposits when deposited to bank coded to accounts receivable to clear Undeposited Funds. Reconcile accounts receivable and provide the client with a report of outstanding invoices. Post all purchases to Accounts Payable using the date on the invoice. Code purchases to expense or prepaid, regardless of payment type. Amortize prepaid expenses over the remainder of their useful life. Keep the prepaid account with a zero balance. If you have a prepaid that does not amortize, place it in a separate prepaid long term asset account. Post cheques, debits, and cash or credit payments at date of payment. Code all payments to accounts payable to clear the sub-ledger and credit the appropriate bank or other account, such as the shareholder loan account for cash or personal payments. Reconcile Accounts Payable and provide the client with a report of unpaid bills. Reconcile bank accounts, credit card statements. Amortize property and equipment over the remainder of its useful life. Other adjustments for year end. Timing: If you don’t have time to post purchases and amortize prepaid expenses, post them later when the bank is reconciled. It is more important to post your sales, clear your deposits, post your payments and reconcile the bank than it is to post purchases, unless you are using a Time and Billing system to bring your purchases forward to your Sales invoices, in which case, you had better post your purchases before your sales. 5. Reconcile all business and personal bank accounts, credit cards and supplier statements monthly and file in separate folders for each account. Staple all of the documentation for each bank © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 3/21 account to the statement including cancelled cheques, deposit slips, deposit information submitted by the customer for the reason for payment, which often makes no sense unless it’s with the deposit slip as there often is no identifying information other than an amount, someone else’s cheque # and a bunch of invoice #’s, any money orders or drafts purchased to pay for supplies or services. 6. Keep the purchase document and the credit card payment slip together and file the credit card purchase documents alphabetically in the payables files. When you post the payments to the credit card account, post the payments for business reasons as payments to Accounts Payable. 7. Keep all business and personal bank statements with all of their attached documentation as well as credit cards statements by account by year in separate files for each account. File the most recent month on top. 8. Invoice all sales. Produce 3-part invoices: part one for the customer, part two file in numerical order for accounting purposes and part three file in alphabetical customer files. 9. Keep a file for all residential or commercial tenants with their contact information, how much rent they paid you, rental agreements and correspondence. For commercial tenants including home based corporations, GST registration may be required. For short term tenants, PST and/or hotel tax may be required. 10. Deposit all money received from sales intact to your business account. This makes it easier to clear the accounts receivable sub ledger by customer and to provide a clear trail of all transactions. If you keep the cash, it means you have to find a way to communicate the date and the amount received to the accountant later. Any time there is missing information, it costs you, because it takes time to reconcile accounts for missing transactions. 11. Document the source and reason for receipt of funds on all of your deposits, business or personal, bank or credit card, no matter whom they are from or what they are for. Taking care of revenue means taking care of business first. Focus on revenue generation first so you will have the funds to pay expenses. © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 4/21 12. Tear out your deposit information from the deposit book. Staple the information that came with the deposit from the customer to the back of the deposit slip that you keep for your accounting records. Don’t leave your deposits or the copies of your receipted deposits in your briefcase or car as replacing that information is almost impossible if it is lost or stolen. Over the years, I have at least one client each year whose briefcase is stolen with their deposit book in it. Until the bank statement arrives, tear out the daily deposit information and backup materials and put the posted deposits in the front of the bank statement file. Match and staple these deposits along with cancelled cheques to the back of the bank statement when it arrives at month end. 13. Never remove cash physically from one account and deposit it to another account at another branch or bank. It will look suspiciously like double the revenue was earned. An auditor will think that the new deposit is not the same money as the money that was withdrawn from the other bank. Leave a paper trail from bank to bank or account to account with electronic transfers or cheques. It’s too easy for an auditor to say, ah, that’s new money, not the money you took from the other account, even if it was the same day. I don’t know how many clients I have seen over the years that take money from their business account, walk across the street and deposit it into their savings account. It’s probably some childhood savings technique gone awry; either that or I’ve been duped for years. 14. Write why (business reason) and if applicable, especially for cost of sales or for meals and entertainment or reimbursable expenses who it’s for (customer or supplier or other name) on every purchase document. It makes for easy identification of cost of sales to match sales and costs and is required in order for the bookkeeper to ascertain which expenses are personal and which are business. Who wants to pay their bookkeeper to enter a bunch of personal expenses only to have to re-categorize them later as shareholder loan or proprietor’s draws? That’s a waste of time and money, not only that, but the Civil Penalties rules require that the owner/manager, accountant or bookkeeper ascertain what is business and what is personal before it’s entered. You are just helping them do their job. The exception is when you record vehicle expenses and home office costs and allocate a reasonable portion at the end of the year, adjusting out the personal portion of the GST claim, same with 50% of the © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 5/21 meals. The GST/HST administrative rules allow for an annual adjustment of GST Input Tax Credits. 15. Don’t code purchases or income to “Miscellaneous”: Use clear coding choices. See the CRA Business and Professional Income Guide T4002 for examples for self-employed or unincorporated businesses. GIFI Codes are standardized coding of the chart of accounts for corporate tax reporting in Canada. GIFI was established so that corporations who are required to report their balance sheet and income statement with their corporate return would have standardized coding to make comparison between years and analysis of results compared to similar business’s possible by CRA. 16. Document business claims for telephone use, cell phone use, home office and vehicle usage by Km log, stating business reasons and customer names in writing. Again, use ‘B’ for Business and a ‘P’ for Personal to distinguish between business and personal use. 17. Post all purchases to Accounts Payable, regardless of method of payment, be it cash, cheque, credit card or debit card or employee expense account. Have a policy of only accepting original receipts and of keep original receipts in your own records. Provide customers with a copy attached to the invoice if you are requesting to be reimbursed for expenses. Why? You are required to have the original purchase documentation for GST/HST Input Tax Credits claims. Imagine attempting to get back the originals for all of your travel receipts because a GST/HST auditor refuses your ITC claims for all of your reimbursed expenses because you gave away your original receipts. GST legislation requires originals to claim ITC’s and you normally only have four years to claim the credits, two years in larger organizations. 18. Post all purchases as Bills and reduce payables with Payments by source. That makes it easy to see the transactions for each vendor all in once place. Use the Accounts Payable sub ledger as clearing account for all purchases. If you have a payment, but no receipt, or vice versa, the transaction will show up as not cleared. This is what you call exception reporting. It is easy to see that you have not posted the same transaction twice when you review the vendor detail report. The date is usually the biggest clue. Many clients try to pass off the restaurant receipt © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 6/21 one month as cash paid and the credit card slip with the tip included the next month as paid by the credit card. 19. One method you could use for employee or owner expense accounts is to use a separate credit card register to keep track of the liability and payments to each employee or owner/manager for expenses. Here’s how to do it: Write ‘Paid by” and the employee’s name on each receipt rather than keeping them lumped together as a set of receipts. Ditch the spreadsheet method. This way you can compare the purchases to other claims by other employees or owners. Trust me, employee or owner/manager expenses often get claimed more than once and by more than one person with a photocopy of the original receipt or the second claim with the credit card payment slip. Post the Purchases in Accounts Payable Trade and code the debit to expense. Post the amounts paid by the employee from their list of payments to the credit card register account as a liability. Code all amounts paid by employees to Accounts Payable by the vendor name to clear the payable. Remember that you have already expensed the amount when you posted it to Accounts Payable above. If you find that three different people have all been claiming they paid for the same meal, you need to consider your options. Do you approach them asking for proof of payment, do you go back to find out how long they have been doing this or do you just hand back the box and say you are too busy and have a nice life? This really happened to me with a new client and when I investigated it had been going on for years. File the receipts in alphabetical order in the payables files so you can find the receipt by supplier name without having to hunt through employee expense reports to see who paid for it. © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 7/21 Post the payment to the employee to reduce the credit card ‘expense account’. Theoretically the payments to the employee or owner/manager should net against the liability and you could reconcile the account each time to nil. Put a copy of the register report with the total amounts paid with a copy of the payment in the employee file. By placing all purchases in alphabetical order regardless of who paid for them, if you want to see the receipt from a supplier, you will find it quickly and easily. Why would you need to remember who or how it was paid in order to find a receipt? When you are looking for purchases later, you don’t care who paid for them or how they were paid. If it is broken and you want to invoke a warranty, the last thing on your mind is which credit card you used or which account you used to pay for it. 20. File all purchases, no matter how they were paid by vendor in alphabetical order. Use a separate file for vendors whose names start with A, B, C …Z and more individual files for suppliers with more than 10 pieces of paper in a year. 21. If the business is very small, you could use A-B, C, D-F, G-I, J-L, M-O, P-R, S, T-V, X-Z. You would probably create a separate folder for the phone, gas, hydro, their 3 largest suppliers and their favourite stationery store in addition to those 10 folders. Why separate files for C and S you ask? Over the years I have discovered that there are more suppliers whose names start with those letters than any other section of the alphabet. 22. File supplier statements in the same file as the purchases after reconciling invoices and payments to the balance owed as stated by the supplier. Call to reconcile differences or dispute balances owing while it’s still a current item. Rather than waiting for a dunning phone call, take the initiative to make the call and you will often find that you make a friend. Then when there is a problem it’s much easier to talk to the bookkeeper or business owner/manager than if you have never connected before. Being on the end of collections calls is never fun but if you know the person, it takes out the feeling of a sting. © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 8/21 23. Know and implement the Employee or Self-employed criteria to minimize risk (includes spouse and family payroll). See CRA Guide RC4110 and take to heart that if you own the company, you likely are not self employed by the company. Your relationship is that of either a shareholder or an employee. The cost of the CPP is exactly the same whether you deduct it or the company deducts it and yes there will be tax rate differences, but then integration eventually puts you back in exactly the same position. The cost of not doing this could be very expensive. If you hire your spouse as your bookkeeper, they are more likely than not an employee, not likely a self-employed person with their own home office. They may be an employee who works from home and home office costs for an employee would not include the mortgage on the house. 30% of the cost of that second vehicle would not be required driving for an employee to make a weekly deposit and no it is not a daily deposit because there are not daily deposits to the bank on your statements. 24. If you hire your spouse, you must consider what you would pay an arms length third party as wages for similar work and that’s what you should be paying as hourly wages. That means a time sheet and a job description too. Just because they have a University degree in anthropology does not mean that they should be compensated as a University grad when performing bookkeeping, running errands and dropping the deposit at the bank. These are not high paying jobs. Same goes for the kids and when you hire them, pay them so they can pay for the things they want to pay for. Don’t offset it against room and board. Don’t pay their university tuition or their down payment on their car. Pay them and let them spend their own hard earned money that they worked for how they choose. Yes there are barter and exchange interpretations and it is possible that this would not be a problem. The reality is that you likely will get stuck explaining your barter system to an auditor who has no idea what room and board means as their culture does not include such a concept. The fact that the room and board doesn’t even cover the pop and chips they eat will not be taken in with any modicum of sympathy at your plight. Pop and chips may not be a food group they understand. 25. Report contract payments for contractors when required to. © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 9/21 26. Review for elections in IC07-1 TaxPayer Relief Provisions, which has a list of Elections in Appendix A, file all tax returns and elections on time and always keep a copy on file. 27. Review capital cost allowance for your assets every year. Keep a schedule of the capital cost and adjusted cost base of all assets in the pool. When you sell or dispose of an asset, you must always check the proceeds are less than the original cost or claim proceeds and capital gain on the amount over and above the original cost. Check for special pool rules, half year rules, and personal use changes. Ask about any dispositions or disposal of assets due to obsolescence. Do not assume that nothing has changed. There are a number of changes to the capital cost allowance rates and categories every year. 28. Did you know that the CCA on computers changed from the separate pool rules on over $1,000 at 30% to 45% for computers, and were bumped after March 18, 2007 to 55% (not yet passed as of October 2007) but no separate pool? The separate pool rules for computers, did you know that you had to attach a special letter in the year of acquisition? Review for the dates on your computer equipment every year. Notice that there was an expiry of five years on the separate pool rules at which point they rejoin the main pool if they have not been disposed of in which case there could be a terminal loss. 29. Review all of the special rules, notice if you don’t need to claim CCA and discuss whether doing so is a good idea to build up the losses or whether it’s better to defer the claim as the losses would not be utilized in time before they dropped off the table. Watch for recapture on the sale of assets. Always do the full calculations on the split between land and buildings, no matter how awful that calculation is to do. Ask whether there is tenant every year. Did you know that May 1, 2006, the small tools threshold moved from $200 to $500 for Class 12 at which point it moves to Class 8? 30. Always check out the GST/HST rules based on the vehicle type and percentage of use for business in the first year. 31. File all Notices of Assessment, Re-Assessment, correspondence, Notice of Objection and other tax information with the tax returns for ease of review. © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 10/21 32. Keep a separate file for each year for each employee and contract worker. Include copies of pay cheques, summaries, correspondence, TD1, both federal and provincial, T1213, any garnishee orders by banks or government, job descriptions and time sheets for each employee and owner/manager too. Ensure that every employee completes a time sheet and has a job description, especially those who are related to the owners of the business. Document fair market value of wages paid to family. Have a permanent file for each employee as well with their hiring information, resume, any reprimands, kudos and notes. 33. Check for compliance with GST/HST, PST and not just PST in your own province/territory, Excise Duty and Tariffs, Import/Export, Payroll and Benefits, WCB and Provincial Employment Standards. Ensure compliance with regulations with regards to spouse/partner or other relatives. 34. Ensure that km logs are available for all business use of vehicles. Avoid company cars and reimburse all employees and shareholders with a flat, reasonable kilometre rate. 35. Discourage mixed use of personal and business transactions on bank and credit card statements, either for corporations or business. Not only does it take much longer to do the accounting because of the volume of transactions, the less an auditor sees of personal transactions in the business books, the more likely the audit will be short. 36. Keeping books and records up to date is not just a good business practice; it’s actually required by law. Recognition and acceptance of this requirement will make it easier on everyone. 37. Keep documentation for each year as a set of records with copies of your tax return and tax return schedules. Don’t shred or throw out financial records for at least 6 years after assessment or reassessment. Information Circular 78-10, Books and Records Retention/Destruction, and its Special Release. If you want to destroy your books, records and related vouchers before the minimum six-year period is over, you must first get written permission from the Director of your tax services office. To do this, either use Form T137, Request for Destruction of Books and Records, or prepare your own written request. © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 11/21 38. General Ledger review is essential. The other day I reviewed a potential client’s books only to find in excess of $300,000 in negative revenue posted to expenses and vice versa, $200,000 in expenses posted as revenue. Schedule regular review with client and accountant for all transactions (monthly, quarterly, annual) Review reasonability of all tax returns, whether payroll, GST/HST or PST every time a return is filed Adjust for personal component of GST/HST at year end for vehicle or asset use, 50% of meals, home office use etc. Review for o Capital versus income o Revenue and expense coding o CCA classes o Prepaid o Bank reconciliations o Accounts receivable aging and collections o Accounts payable unpaid or not posted o Accruals 39. Policies and Procedures Manual can become critical in the event of an unforeseen disappearance of a key player like your bookkeeper. Have one and know where it’s kept and schedule a regular review every few months to check that it’s still current. Even if it only has some basic things in it like these ones below so that you can access the data or figure out how to get the billings out so you can pay wages or payroll liabilities which general huge penalties for late payment in an emergency. If you don’t have a description of how to do any of these things if the bookkeeper gets hit by a bus: Obtain passwords to computers, data files, both accounting software and spreadsheets or other medium, Obtain internet access to internet sales requests, Obtain access to online banking (your bookkeeper should not have access to this unless it’s restricted for Bill Payment or Transfer and only allows for data access) Locate backups of the data files Understand the naming conventions used for file storage Accumulate information from sales orders to invoice customers Record sales on an invoice to get billings out to keep cash coming in © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 12/21 Record purchases to pay bills Enter bank transactions to reconcile the bank balance to the book so you don’t write cheques when the bank doesn’t have enough money Figure out who owes you money to collect Calculate and pay critical payments on time, i.e. payroll withholdings and GST/HST, PST, WCB or Income Tax Find the cheques Pay Bills Know who the signing authorities are and have alternatives in case of emergency Know who has power of attorney and what the limitations of that power of attorney are and where the power of attorney is located in order to present it as proof of ability to sign © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 13/21 Checklist of Annual Files: Every business bank account in a separate file by account with reconciliations for each month Personal bank accounts of owners/partners/proprietors in a separate file for personal tax clients Every business credit card account Every personal credit card account for owners/partners/proprietors/personal tax clients Sales (numerical) Customer file for each customer (permanent) Purchases (alphabetical) GST/HST reports/reconciliations/correspondence Excise reports/reconciliations/correspondence Import/Export reports/reconciliations/correspondence PST reports/reconciliations/correspondence WCB reports/reconciliations/correspondence Employee file for each employee (Permanent) T1 for each taxpayer, shareholder, spouse, relative T2 Corporate returns/assessments/correspondence T3 Trust returns/assessments/correspondence T4 and PD7A Payroll Summary/PIER reports T5 Dividends and Interest reporting Contract payment reporting General Ledger – paper or electronic copy as required (see electronic record keeping IC-05) Working paper file Working paper for intercorporate or non arms length transactions Foreign reporting requirements Log of Days out of the country Km Log for each person claiming business use of vehicle(s) General Correspondence © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 14/21 Checklist of Permanent Files: 1. All investment account statements and information for each account since inception. This includes both RRSP and non registered investments. Checking over-contributions of RRSP’s now that the Attorney General pointed out to CRA that they weren’t auditing. Verify Proceeds on a deemed disposition of an investment to an RRSP since brokers don’t provide that information on the disposition reporting T5008. All of this documentation is required to prove the calculation of the adjusted cost base of each investment; especially if there are capital losses to carry forward that are not used up. You can’t toss those loses until you use them up and then you must keep them for another 7 years past that. 2. All information about the cost of each property, plant and equipment in a separate file. Required when you sell assets, including principal residence, business and personal assets with or without a rental suite, rental property, boats, cars or motor homes. Records of change in use from personal to business use or vice versa. Calculations of opportunity cost of benefit foregone as well as fair market value rent for personal use, especially for condo’s at Big White which were targeted by CRA under a special project last year. 3. Information about tax values such as PUC (paid up capital) and/or ACB (adjusted cost base) for all major assets and shares, Capital Dividend Account balances (CDA) 4. All information about the debt associated with each acquisition of property, plant and equipment. Include your home mortgage documentation as you may be required to prove that the amount you owe today is the original amount borrowed or that you have claimed an appropriate percentage of the mortgage interest compared to the original mortgage. 5. All information about each customer should be kept in a set of customer or contract files. Customer files could be broken down into a number of files for each customer if there is significant volume of information about each customer including Permanent, Correspondence, Billing, Contract, and Job or Project files. 6. Minute books should be kept at the lawyers office, not your office, but you might have copies of relevant sections of the Minute Book on hand to refer to in a file 7. Financial Statements and reports for management 8. Tax continuity schedules for retained earnings, dividends 9. Audit Correspondence and Statistics Canada reporting © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 15/21 Audit Checklist Require documentation to record: All sales, purchases, deposits, payments All credits/transfers from Retained Earnings All payables to shareholder/proprietor All prepaid amounts All capital acquisitions and dispositions Required for all employees on payroll, especially for shareholders and their relatives Time sheets Tasks completion reporting Job descriptions Ensure that: There are contracts for employment, especially for shareholders and their families and essential if there is a PHSP as it would be invalid without one Dividend transactions are recorded in the minute book and recorded appropriately Bank accounts and debts are all listed and activities recorded and reconciled All receivables are collected – keep a full set of books for self-employed persons Bad debts/reserves are documented as to the reason and current status All reimbursements of expenses are recorded as revenue and GST is charged All purchases have documentation about business reasons All balance sheet accounts are reconciled and working papers prepared for contents of each account even if it is nil start/finish – use the GL to check for accounts with transactions but no balance beginning or ending Posting of purchases All purchases through payables and reconcile to suppliers payments Prepaid amounts and capital amounts to asset accounts from payables Only record business purchases through the business books Adjust GST on personal items prior to filing tax returns Adjust GST claims annually for personal portion of meals, auto expenses, personal expenditures and ITC claims on business use of personal vehicle © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 16/21 Adjust UCC of vehicles on T1’s for ITC’s claimed for business use of personal auto’s Ensure all potential GST registrants are identified When paying people for any services require: TD1’s for all employees with SIN and birthday, address and contact information and signature (Check SIN for 9’s – Work Visa) All contractors be self-employed or require Rulings for questionable circumstances Invoices and contracts for all contractors BN #’s and invoices – no cash deals All barter transactions recorded at fair market value Review records each year before filing T4’s in February to ensure: T4’s include all taxable benefits for all employees, directors and officers Records are up to date for the year to December 31, not just the last year end Review for T5018’s - Contractor Payments Promptly review/respond to any PIER reports or queries from payroll section Ensure T4’s or T4A’s as appropriate are issued for other payments including shareholder benefits and loans not repaid or a series of transactions re S.15 Ensure that T5’s are filed for all reasons including interest and dividends and include S.80.4 interest on shareholder loans in a debit position File all slips, returns, elections and returns on time Ensure that taxpayer is in compliance with all laws, not just tax, but Provincial taxes and laws, WCB, etc. Ensure client is registered for PST and research that they are in compliance with regulations for both sales and self-assessment of purchases Downloading software Norton Anti-Virus Used goods New goods over the internet from out of province or country Ensure client is registered for WCB Corporate Self-employed and hiring sub-contractors or employees Ensure employer/client has policy and procedure To obtain Clearance Certificates for sub-contractors who pay their own coverage © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 17/21 To identify Personal Services Business Corporations who should be covered To identify self-employed individuals without WCB who should be covered Calculate Capital Gains Dividend accounts and update each time there is a change during the year Reconcile financial information to tax returns for capital assets, reserves and deferrals of tax every year in the working paper files Reconcile Retained Earnings every year for continuity to ensure that there are no entries from Retained earnings to shareholder loan accounts that are then paid out to shareholders without a dividend declaration File returns on time as late filed returns are a flag for audits Advise employers/clients when certain items will almost certainly trigger an audit Discourage any personal expenditures posting in the records Document payments to all related persons, officers and directors with explanations, contracts, time logs, documentation of reasonability and fair market value Determine personal use and document with appropriate personal/business use of company assets and record personal use benefits Document fair market value of all transactions with shareholders and related parties with independent appraisals Avoid companies owing cars or ski condos, Reimburse tax free km’s from km log documentation Reconcile shareholder accounts and monitor for S.80.4 interest and S. 15 benefits, record all shareholder transactions in the shareholder accounts, do not mix in with trade receivables and/or payables Recommend taxpayers keep all personal banking, credit, debt statements with their tax returns as CRA auditors will require them and if not available will insist that taxpayer pay for copies and explain deposits Require documentation/explanation for all deposits to all bank, credit and loan information for corporate and personal accounts Require accounting of all investment portfolio accounts and tracking of ACB to FMV for both corporate and personal investments, not just the slips for what was sold this year if they can find them Identify all related parties and monitor for fair market value of transactions between parties Track personal net worth © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 18/21 Assist with budgets for personal expenditures and income In practice, consider a policy of ‘the big picture’ and full inclusion of all work for all related parties as it is easy to bury related party transactions when you do not see the big picture. What for: If clients ‘divide and conquer’ consider if you are missing the big picture If you do the tax for one corporation Someone else does another corporation or trust They prepare their own personal returns Communicate clearly with everyone involved Auditors Clients Employees Employers Document everything Obtain advice when unsure how to proceed to: Minimize risk Maximize client service © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 19/21 Checklist for your files about the client: Check in with yourself about your own documentation Review engagement letters to ensure they include service in event of an audit, if not refer to CGA Public Practice Manual for specific engagement letter Prepare a new Engagement letter to explain what services you will provide during an audit and set standards about what you expect from your client Good idea they may not want you to assist and you might not want to either Before you agree to take on the work… Do not be afraid to recommend someone else handle the audit Do not take on the audit work if you do not have enough time or the expertise. Find expert help, ensure you have adequate staff and expertise in your practice to handle the increased workload Seek other professionals on a contract basis to assist or recommend that the client seek other experts Organize your files and client communications to ensure you know what is in your files Obtain advice if you are not sure: If you are an employee, involve and obtain professional advice from the organizations auditors and lawyers or your own if you are not confident of their advice Recommend employer/client obtain legal advice from a tax lawyer Obtain legal advice for yourself from a tax lawyer who is competent to handle this specific type of legal work Call CGA BC public practice advisor, Tina Peters to discuss how best to proceed (even if you are in industry, you can call her and she is sworn to secrecy) Hire a practice mentor or a CGA with audit experience to help you if you do not have experience Any technical areas that you are not sure of, research and ask other professionals with experience right away If there is any potential for an insurance claim, notify your insurance carrier, ask how to proceed and take their recommendations seriously. It is up to you to work with the owner/manager/client to mitigate claims. Review your procedures to determine how you could reduce risk of another audit by having sufficient documentation © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 20/21 Checklist for Auditor Visits: Start an audit file for each audit to keep all correspondence and notes about the audit, the auditor and the findings Record and document all conversations with CRA with names, dates, times, attendees Be ready for CRA request for electronic and paper files and communications including Documents, correspondence, contracts, payroll and HR Your working paper files, special project files Electronic records such as Email, Word files, Notes, Outlook calendar, Excel spreadsheets and General Ledger Owner/Manager’s personal net worth, assets listing, bank accounts, credit, debt, investment transactions Logs including Km, Meetings, Inventory records, Tracking documentation for jobs/shipments Correspondence, Contracts, Calendars and Day Timers Minute books and other legal documentation Audits should trigger an internal review. Update Policy and Procedure Manuals to ensure you have a clear statement of standards for Record Keeping and edit the manuals with any findings Ensure procedures and standards have/are being followed Review/Talk about your Policies and Procedures with CRA, employer, client, staff, employees Use the audit as the perfect time to introduce/raise standards if you are feeling uncomfortable about current procedures and policies or something comes up during the audit that you were not aware of: Capitalize on the audit to raise the bar Listen carefully to the audit questions/ask the auditors for areas you could improve on Question why you were audited and if you are audited frequently what has put you on their radar? What could you do differently that would reduce the number of audits you are experiencing? Are there standards you could set, internal controls, policies and procedures you could implement to reduce the risk of audits? Keep the audit file for each audit with the permanent records as you may find it useful to refer to it in the future when reviewing your standards, policies and procedures Eileen Reppenhagen, CGA, Certified QuickBooks ProAdvisor writes and speaks about accounting and tax. Visit her website at http://www.taxdetective.ca © Copyright 2007 Eileen Reppenhagen 3/8/2016 Page 21/21