Navigating the Pandemic Unemployment Assistance Program

Expanded Unemployment Benefits for the Self-Employed and Others

The U.S. Department of Labor recently announced the publication of the Unemployment Insurance Program Letter (UIPL) providing guidance to states for implementation of the Pandemic Unemployment Assistance (PUA) program, a provision under Section 2102 of the Coronavirus Aid, Relief, and Economic Security Act (CARES). Pandemic Unemployment Assistance provides temporary “unemployment” assistance to those individuals not traditionally eligible for unemployment benefits, and affected by COVID-19, including the self-employed, independent contractors, and gig workers. 

Eligibility

Eligibility appears very broad. Section 2102 provides for payment of PUA to “covered individuals,” defined as individuals not qualified for regular unemployment compensation, extended benefits under state or federal law, or Pandemic Emergency Unemployment Compensation (PEUC), including those who have exhausted all rights to such benefits. Individuals seeking part-time employment, individuals lacking sufficient work history, or those otherwise not qualified for regular UC, extended benefits under state or federal law, or PEUC  are also included. For purposes of PUA coverage, an individual “lacking sufficient work history” means an individual (1) with a recent attachment to the labor force (2) who does not have sufficient wages in covered employment during the last 18 months to establish a claim under regular UC, and (3) who became unemployed or partially unemployed because of one of the COVID-19 related reasons identified under Section 2102. 

Examples of Inability to Work

Under Section 2102, reasons for an inability to work include:

• The individual has been diagnosed with COVID-19 or is experiencing symptoms of COVID-19 and seeking a medical diagnosis; 
• The individual is providing care for a family member or member of the individual’s household who has been diagnosed with COVID-19; 
• A child or other person in the household for which the individual has primary caregiving responsibility is unable to attend school or another facility that is closed as a direct result of the COVID-19 public health emergency and such school or facility care is required for the individual to work; 
• The individual is unable to reach the place of employment because of a quarantine imposed as a direct result of the COVID-19 public health emergency; 
• The individual’s place of employment is closed as a direct result of the COVID-19 public health emergency.

A qualified individual’s benefit equals the amount the person would have otherwise received under state law plus $600. Section 2102, however, explicitly excludes from coverage individuals who can work remotely with pay and individuals who are receiving paid sick leave or other benefits (even if they would otherwise qualify for unemployment under the CARES Act).

Further Information

The process for applying for these benefits will vary from state to state. For more information on whether you may qualify for Section 2102 benefits, and how to apply, please contact the Rhode Island Department of Labor and Training or the Massachusetts Department of Unemployment Assistance.

If you have any questions, please reach out via e-mail, give us a call at (401) 921-2000, or fill out our online contact us form.

For more information on COVID-19 and to get the latest updates, visit our COVID-19 Resources page.

While challenging times can bring out the best in people, there are also individuals who view these times as opportunities to prey on those most vulnerable by trying to steal money, identities or both. The novel coronavirus (COVID-19) pandemic has caused significant disruption to both domestic and international economies and led governments to impose various forms of social, travel, and work restrictions. As a result, there are many people in our communities that are experiencing significant financial hardship. The Coronavirus Aid, Relief, and Economic Security (CARES) Act was recently signed into law and is designed to bring assistance to those in need. 

One of the items included in the CARES Act is a direct stimulus payment (economic impact payment) to individuals, married couples, and children who qualify. The CARES Act provides direct payments of up to $1,200 for single filers and $2,400 for married couples filing jointly, plus $500 for each child under 17. Children who are, or can be, claimed as dependents by their parents aren’t eligible individuals even if they have to file a return. Income limits apply, for single filers the phase-out range begins at an adjusted gross income of $75,000 and completely phases out at $99,000. For married couples the phase-out range begins at $150,000 of adjusted gross income and completely phases out at $198,000. 2019 tax returns, if they have been filed, will be used to determine eligibility. If a 2019 tax return has not been filed yet, the payment will be based on the 2018 return. This means that taxpayers who receive a smaller payment than they are eligible for based on 2020 income will receive the difference after filing a 2020 tax return, but overpayments due to a higher income in 2020 are not expected to be due back.

This provision provides relief for individuals and families who are struggling financially right now, however, the desire to receive this money quicker leaves people vulnerable to scammers. By keeping the following in mind, you can protect yourself, and those you care about, from falling victim to fraud:

The federal government will NOT contact you. Federal offices will NOT contact individuals directly via phone, email, or text to verify personal or bank information. If someone contacts you claiming additional information is necessary to process your economic impact payment, immediately cease communications and report the number or email address.

There is not a faster way to get the economic impact payment. If someone claims they can expedite your check, know that this is a scam. Currently, the payments are expected to go out in the next three weeks. 

You do not need to pay anything! There are no processing fees involved in receiving your economic impact payment. If anyone contacts you regarding a small fee to authorize the payment, know that it is a scam.

Communicate directly with the IRS. If you’d like to set up a direct deposit of your stimulus payment, communicate only with the IRS directly. The United States Department of the Treasury plans to develop a web-based portal for individuals to provide their banking information to the IRS online, which will streamline distribution. If your bank information was already provided to the IRS on your 2018 or 2019 tax return, no further action will be required. If the federal government does not have your bank information, they will send a hard check to your home address.

No need to sign up or file a simple tax return. Social Security recipients who are not required to file an income tax return will not need to file a simple tax return to receive a payment. Rather, the economic impact payments will be automatically deposited into your bank account, as is the case with the normal monthly payments received.

Watch out for fake checks! Some people have reported the receipt of economic impact checks in the mail for odd amounts, including ones with cents. It is going to take the United States Department of the Treasury a few weeks to mail out hard checks, so if you receive one too early, it is likely a scam. Also, these early, fake checks may ask you to verify the check online or by calling a certain number; these are signs of a scam!

If you do identify any coronavirus-related scams, you should report them to the Federal Trade Commission.

Hopefully, the information above will provide you with the awareness and information that you need to avoid falling victim to a scam related to the economic impact payments. We are all in this together, and together we will make it through this stronger than ever. If you have any questions related to the economic impact payments and/or the CARES Act, our team of professionals stands ready to assist you. Please give us a call at (401) 921-2000, or fill out our online contact us form.

For more information on COVID-19 and to get the latest updates, visit our COVID-19 Resources page.

Like many others, your company has likely transitioned many of its staff members to a work-from-home model. This is a good time to remind everyone to be diligent in checking for potential malware and online scams. While many people are adjusting to working from home for the first time, they are also being asked to homeschool children or care for elderly family members. This distracting environment makes it easy for employees to inadvertently click a bugged link or document, thereby introducing malware or ransomware into your systems.

Recently, we’ve seen reports of the following phishing scams:

• Fake coronavirus maps and websites – there have been numerous attempts of malware on sites that offer fake maps of the spread of the virus. We recommend you only use trusted news sources like CDC.gov.
• False ads for masks and protective gear – again feeding on people’s fears, scammers are pushing malware or phishing for personal information through sites claiming to have protective gear for sale. We recommend shopping local, or through a known online retailer.

COVID-19 has already caused countless interruptions to our daily lives, but we urge you to mitigate additional long-term business disruptions by offering your employees frequent reminders about these online risks.

For additional information about coronavirus scams, please reference the FTC’s consumer information page. If you have any concerns regarding your company’s finances, please contact us.

For more information on COVID-19 and to get the latest updates, visit our COVID-19 Resources page.

Resources Available to Help Your Business and Family

As you’ve probably noticed, more and more businesses are temporarily closing their doors each day. Some of them working remotely, some providing free shipping options, and others just closing completely for the time being. With all of the uncertainties surrounding COVID-19, chances are you and your business are feeling the impact as well. You can rest assured that government agencies are hard at work creating programs to provide support to ease the burden on businesses, individuals, and the economy.

Here are some of the resources currently available:

1. For when you need to make a plan – The Rhode Island Society of Certified Public Accountants (RISCPA) knows how critical it is for businesses to prepare for the future, especially as we don’t know how severe COVID-19’s impact will be. Refer to their COVID-19 Business Planning Checklist to make sure your business is ready, here.
2. For when COVID-19 has taken a bite out of your revenues – The U.S. Small Business Administration (SBA) is offering low-interest federal disaster loans up to $2 million. These loans can be used to help meet financial obligations and operating expenses that would have been met had the disaster not occurred. This SBA assistance is available in the entire state of Rhode Island and the counties of Bristol, Norfolk, and Worcester in Massachusetts. Visit SBA.gov/disaster to confirm eligibility and start the loan process.
3. For when your employees are unable to work due to a public health emergency – The Families First Coronavirus Response Act was signed on March 18, 2020 and takes effect on April 2, 2020. The Act provides the following provisions:
   1. Emergency Family and Medical Leave Act (FMLA) Expansion
   2. Emergency Paid Sick Leave Act
   3. Employer Tax Credits for Paid Sick and Paid Family and Medical Leave

For more specific details on the provisions under the Families First Coronavirus Response Act, see our recent email update.

4. For when your business is working remotely – Microsoft is providing six months of its Office 365 tools for free to enable remote collaboration, file sharing, and video conferencing. Access this free service, here.
5. For when you’re out of work due to COVID-19 – The Rhode Island Department of Labor and Training (DLT) is processing COVID-19 related unemployment insurance claims faster and more generously. Visit their website for more details on how to apply.
6. For when your child’s school is closed – “Grab and Go” meals are available for children at various sites throughout Rhode Island. There are no ID or residency requirements, but the child must be present; schools cannot give a meal to an adult on behalf of a child. Click here for a list of food sites and their respective hours.
7. For when your child is completing their schoolwork in a remote environment – Cox Communications is offering its low-cost internet service to families that don’t have an internet connection at home for free for the first 30 days. They are also partnering with PCs for People to allow families to purchase discounted, refurbished computers. Click here for more information.
8. For when your accountant’s office has temporarily closed – On Friday, March 20, 2020, the IRS issued Notice 2020-18, which automatically extends the filing and payment due date for Federal income tax returns from April 15 until July 15th for Affected Taxpayers. This notice only provides relief for Federal income tax returns and Federal income tax payments. For information on state income tax filing and income tax payment deadlines and extensions see the American Institute of Certified Public Accountants (AICPA) State Filing Relief Chart for Coronavirus, here.

DiSanto, Priest & Co. is still open! Although we are working remotely, we are still here to support you with all your business needs. Please reach out, just as you always have, via e-mail, give us a call us at (401) 921-2000, or fill out our online contact us form.

For more information on COVID-19 and to get the latest updates, visit our COVID-19 Resources page.

The new tax law, 26 U.S.C. § 162, has left rental real estate owners wondering whether they qualify for the new 20% deduction for qualified business income (QBI). While final regulations indicate that stand-alone, triple-net lease rentals would not qualify for the QBI deduction, there are three alternate paths in which rental activities could qualify for the deduction: 

1) As a Section 162 Trade or Business 

To qualify for QBI as a Section 162 trade or business, the taxpayer must meet certain facts and circumstances requirements. Case law requires a Sec. 162 trade or business to have a profit motive and pursue considerable, regular, and continuous activity. For example, a hobby would not qualify as a trade or business. The final IRS regulations list several factors to consider when determining whether the rental activity is a Sec. 162 trade or business:

• Type of property rented (commercial vs. residential)
• Number of properties rented
• day-to-Day involvement of the owner or the owner’s agent
• Terms of the lease
• Type and significance of any ancillary services provided under the lease

2) As a Rental to a Related Party

The final regulations state that if the rental activity qualifies as a trade or business, it should be consistently treated as a trade or business under other U.S. Code sections. The taxpayer should also comply with the requirements under Sec. 6041, such as filing required 1099s if assuming the position as a trade or business. 

The final regulations offer clear guidance on related party rentals. The rental activity qualifies for the QBI deduction if the rental party rents or leases to an individual or pass-through entity that is commonly controlled. To be considered commonly controlled, the same person or group of persons must own at least 50% of the rental activity and the related trade or business. If the related party is a C corporation, it will not qualify under this rule. Also, if the income of the related party is derived by an activity that is classified as a specified service trade or business (SSTB), the rental activity will treat any rental income from the SSTB as SSTB income when calculating the QBI deduction.

3) As a Rental that Qualifies Under Safe Harbor

A rental activity will also qualify for the QBI deduction if it falls under the safe harbor rule, through Notice 2019-38. To meet the safe harbor requirements, the taxpayer must satisfy the following factors during the taxable year:

• Maintain separate books and records to reflect income and expenses for each rental real estate enterprise
• For rental real estate enterprises that have existed for less than four years: a minimum of 250 hours of rental services are performed per year
• For other rental real estate enterprises: in at least three of the past five years, a minimum of 250 hours per year of rental services were performed
• Maintain contemporaneous records, including time reports, logs, or similar documents, regarding the following: 
  • Hours of all services performed
  • Description of all services performed
  • Dates on which such services were performed
  • Record of who performed the services
• A statement is attached to a timely-filed, original tax return for each taxable year that the taxpayer relies on safe harbor

These records must be made available for inspection at the IRS’s request. The contemporaneous records requirement applies to taxable years as of January 1, 2020.

To meet the safe harbor rule, taxpayers can combine activities that produce the same type of rent to form a rental real estate enterprise. Thus, commercial rentals can only be combined with other commercial rentals, and residential properties can only be merged with other residential rentals when consolidating activities into a single real estate enterprise.

The self-rental and safe harbor regulations provide clear-cut paths for qualifying for the QBI deduction. Other rental real estate activities may also qualify under Sec. 162 as trade or business activities, however, they need to be analyzed on a case-by-case basis. 

If you believe you could qualify for this deduction and need help navigating this area, feel free to call Jessica Corvese at 401-921-2000 or email jcorvese@disantopriest.com. Be sure to follow us on LinkedIn to stay informed on the latest tax updates.

Any successful company motivated to grow its sales volume should first focus on the existing relationships it has worked so hard to build. As a best practice, companies should leverage and revitalize current areas of business before tapping resources to develop new product lines and expand selling opportunities in existing markets.

In Inc.com’s article, 7 Powerful Strategies for Strong Sales Growth, Drew Greenblatt advocates for increasing efforts with current clients first, “All the systems are set up. The team knows how to make it right. Stick to your knitting and grow market share in what you do best already.…exploit this foundational portion of your business to get the easiest quickest sales.” 

See below for how your company can handle existing business in different ways, leading to growth opportunities and an overall stronger customer base.

Become more customer-centric than market-oriented. 

Approach client management and new revenue development as separate functions. Understand your client portfolio, strategize new engagement opportunities, and direct resources accordingly. Nurturing these existing relationships can also give way to lucrative cross-selling and upselling opportunities. Appreciate that customers within the same industry may have unique needs and purchasing criteria, and create individualized sales plans for each customer. 

Embrace the digital economy. 

Networking and maintaining relationships used to mean face-to-face meetings with current and prospective customers, but nowadays, the internet is the mainstream transaction tool. It is integral to building and nurturing customer relationships, generating sustainable growth, and promoting brand awareness. Invest in a well-coded website to increase your Google search ranking and “inbound marketing” opportunities – make it responsive, mobile-friendly, and easy for customers to access the information they need. Use social media and email marketing to broaden your digital reach, take advantage of direct customer access, and keep buyers engaged.  

Expand your existing product range with complementary goods or services that meet your customer needs. 

To expand within your existing market, a competitive scope grows revenue while increasing the value you provide your customers. While this may seem like a large undertaking, you can readily implement this strategy by outsourcing to other companies that are willing to produce under your brand name. Outsourcing minimizes production investments, allows your firm to focus on its core mission, provides autonomy in choosing suppliers, and creates access to current technologies.

Boosting flat-lined sales can be challenging, but these strategies employ relatively modest investments that build on pre-existing, successful relationships. The strategies all support one main goal: to communicate to target customers that your firm is committed and has the bandwidth to address their growing needs. For more information on how your company could benefit from these recommendations, contact us. Follow us on LinkedIn for more industry insight on growing your business.

Despite continuous sector growth, it remains no secret that industries across the board are currently facing a wide range of challenges impacting their bottom lines. For private business owners, skyrocketing expenses, skilled-labor shortages, and recent changes to the tax laws may lessen their ability to effectively compete within the marketplace. Many industries face similar barriers in achieving sustainability and financial success, therefore opportunities to optimize cost savings and increase earnings potential are ever important. For this reason, there has never been a better time for businesses to determine their eligibility for the employment-based Work Opportunity Tax Credit (WOTC).

Established in 1996, the WOTC is one of the most widely used federal tax incentives to date. The purpose of the WOTC is two-fold, in that both employers and employees can benefit. First, the WOTC aims to encourage businesses to hire from designated target groups within the workforce. Upon hiring these specific individuals, the employers receive compensation by means of a reduction in income tax liability. By reducing your tax rate, your business could benefit tremendously from reduced costs and surplus cash flows. Of equal importance is the WOTC’s solution of leveraging hourly-wage and entry-level individuals who are well equipped and openly available to fill the workforce shortage, which effectively solves two issues simultaneously.

The WOTC also benefits the individual employees comprising the 14 target groups published by the Department of Labor. Typically, the individuals within these groups are under-employed, such as disabled veterans, seasonal workers, or homeless community members. Besides the obvious benefit of gaining employment, the WOTC assists employees by building confidence, reducing their reliance on federal aid, and learning new skill sets. By incentivizing the employment of target groups, the WOTC provides greater opportunities for quality jobs which otherwise may not be obtainable.

Although the WOTC may sound like a complex undertaking, the benefits it produces are undeniable. The first step for a business in any industry is to speak with a tax professional and determine eligibility. In an economy where prices continue to rise, pressure to meet demands grows, and the workforce needed to get the job done is dwindling, determining your eligibility for the WOTC is definitely worth the call.

Please contact us at (401) 921-2000 or email John Rainone at jrainone@disantopriest.com to learn more.

The Federal Reserve’s incremental adjustments to interest rates in the past year have manufacturers reconsidering how to address capital investment needs. Multiple factors can affect whether a company chooses to lease or buy – the return on investment, cash flows, and the productive life of the asset. Generally, the cost of capital is at the top of the list. The low cost of borrowing money over the past ten years tipped the scale toward choosing to borrow and purchase, rather than lease equipment. However, with the prime rate now at 5.0, the choice has become a little murkier. Locking in a borrowing rate now for anticipated purchases over the next year is one short-term solution for which there is generally a premium attached. Even under circumstances where a business has the cash to make capital purchases outright, it may still make better business sense to consider fair market value (FMV) leasing. 

There are a variety of benefits of FMV leasing in today’s market:

• Avoiding the burden of asset obsolescence: This benefit is most apparent when considering purchases of technology and software. Life cycles for these assets typically fall within a 3-year range, which generally coincides with their leasing periods. Upgrades are a natural progression in a leasing program, and in some cases, can be made before leases expire, depending on the agreement.
• Improved cash flow and liquidity: While the purchase of a capital asset requires payment or a significant down-payments and fees upon delivery, lease payments typically begin after the equipment is operational. Without committing to a significant cash outlay, the company can direct cash towards investments in its business versus its infrastructure. 
• Flexibility: Generally, the lessee has options to purchase some or all leased equipment at termination; therefore, taking the risk out of committing to a purchase at the onset.  Leased assets are quicker to obtain and tend to be more flexible than equipment loans giving a business the perspective that time brings into the final decision.

GAAP’s new lease accounting standards, Accounting Standards Update (ASU) 2016-02, have added a new metric, further blurring the lines between owned and leased assets from an accounting perspective. The standards, effective by 2020, re-characterize leasing arrangements whereby a lessee’s contractual access to leased property represents an asset, and the related future obligation to pay for that right is debt. Owned and leased assets will basically tell lenders and vendors the same story about your business; removing the advantage of one over the other from a business reporting stance. (See more about ASU 2016-02 at DiSanto, Priest & Co.’s blog, THE NEW LEASE ACCOUNTING RULES – JANUARY 2020 IS NOT THAT FAR AWAY).

If you’d like to discuss a strategy that would best suit your company’s capital investment needs, please contact us.

The recent outcome of the Sullivan v. Sleepy’s LLC et al. civil case, and the Massachusetts Supreme Judicial Court’s (SJC’s) interpretation of the Mass General Laws has clarified how employers are required to pay commissioned retail employees. 

On May 8, 2019, the SJC issued a unanimous opinion that, under Massachusetts law, salespeople who are paid solely on draws and commissions are entitled to separate and additional overtime and Sunday pay. Prior to the SJC’s decision, retailers had been hanging their hat on two opinion letters issued by the Massachusetts Department of Labor Standards (DLS) over ten years ago that suggested employers did not need to make separate and additional overtime and Sunday payments to 100% commission employees, provided that the employees receive an amount equal to at least 1.5 times the minimum wage for all overtime and Sunday hours worked. 

The SJC’s decision has marked the end of paying non-exempt, retail employees on a commission-only basis in Massachusetts. State law entitles these employees to separate and additional overtime payments, beyond draws and commissions, of at least 1.5 times the Massachusetts minimum wage (currently at $12.00/hour); and premium pay for Sunday work, also equal to no less than 1.5 times the minimum wage. The court also explained that employers are barred from retro-actively repurposing, or renaming, draw and commission payments as overtime or Sunday payments.

The SJC’s decision is already impacting Massachusetts retailers and other companies that pay on 100% commission/draw basis. Now that it’s clear that draws and commissions cannot substitute for other wage and hourly entitlements such as overtime and Sunday pay, employers must carefully examine their pay policies to ensure compliance. Additionally, they are now obliged to recalculate and pay the amounts their employees are entitled to in overtime pay before a lawsuit is filed — failure to do so could have a significant financial impact. Under the Massachusetts Wage Act, sales people not paid for the shortfall prior to filing suit are entitled to automatic treble damages plus attorney fees. 

For more information regarding the most recent developments in Massachusetts Overtime Statute and the implications it may have on your business, please contact us.

The implementation of the Tax Cuts and Jobs Act in late 2017 has significantly impacted the way companies depreciate their assets. If you own real estate or a business, or if you operate in the real estate or construction industries specifically, you need to learn more about the recent, potentially major changes to the depreciation and expensing rules for business assets.

Section 179

Section 179 of the IRS tax code allows businesses to deduct the purchase price of qualifying equipment and/or software purchased or financed during the tax year. For tax years beginning after December 31, 2017, the allowable IRC Section 179 deduction has almost doubled from $510,000 to $1 million. The maximum asset spending phaseout has also increased from $2.03 million to $2.5 million.

Under the former tax law, qualified improvement property was not eligible for Section 179. However, under the TCJA all leasehold improvements, provided they are made to the interior portion of nonresidential rental property after the building has been placed in service, will be eligible for immediate Section 179 expensing. Any improvements to a building’s interior qualify if they are not attributable to the enlargement of the building, any elevator or escalator, or the internal structural framework of the building. Before the TCJA passed, certain types of building improvements did not normally meet the definition of qualified improvement property because they are improvements made to a structural component of a building. However, under the TCJA the qualifying property for Section 179 expensing has been expanded to include the following improvements to non-residential real property: roofs, heating, ventilation, air conditioning, and fire/alarm protection systems.

Bonus Depreciation

Prior to the TCJA, bonus depreciation was limited to 50% of eligible new property. However, the TCJA reform extends and modifies bonus depreciation to allow businesses to immediately deduct 100% of eligible property placed in service after September 27, 2017 and before January 1, 2023. When 2023 hits, the amount of bonus depreciation will decrease by 20% per year until the end of 2026. Qualified improvement property, which now includes restaurant and retail improvements, as well as tenant and building improvements, has been added as eligible property. Eligible property has also been expanded to include used property, which is a significant and favorable change from previous bonus depreciation rules. Additionally, the TCJA eliminates the requirement that the original use of the qualified property must begin with the current taxpayer. This means that businesses can take bonus depreciation on assets that are acquired from a previous user, as long as the current taxpayer did not previously use the acquired property and the property was not acquired from a related party. The TCJA also added qualified film, television, and live theatrical productions as types of qualified property that are eligible for 100% bonus depreciation. In addition, there is no limit to asset spending in a given year and no limit on the deduction amount that can be taken.

Things to Remember

Businesses must keep in mind that not all states allow bonus depreciation, and therefore, the deduction may need to be added back to income on the respective state return(s). Also, businesses do not have the option to select specific items for the deduction. In a given year, taking bonus depreciation on one asset requires the company to take bonus depreciation on all assets that fall into that respective asset class.

Looking Ahead

The TCJA will help businesses with cash flow issues in particular, because it could potentially reduce their taxable income in the year of the deduction, therefore lowering their tax liability. However, even if your business is not experiencing cash flow issues the TCJA can still be a boon. The TCJA is the biggest tax overhaul since the Tax Reform Act of 1986 and these specific depreciation and expensing changes can have a profound effect on your business taxes. You do not want to miss an opportunity to expense 100% of certain assets and improvements, especially if you are in the real estate or construction industry.

To learn how you can achieve the greatest benefit for your business today, contact John J. Rainone, CPA/MBA, CCFIP at 401-921-200 or jrainone@disantopriest.com.