INSIGHT TO GET IT RIGHT: PREPARING FOR 2017 AUDIT & TAX FILINGS - - PDF document

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INSIGHT TO GET IT RIGHT: PREPARING FOR 2017 AUDIT & TAX FILINGS

June 13, 2017

Nick Wallace, CPA Director nwallace@bkd.com Nicole Fishback, CPA Director nfishback@bkd.com

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• NOT a technical discussion of the details of FASB & GASB

pronouncements

• Provide a practical “how to” session on issues to consider as you

work through this year’s audit & tax preparation plans & prepare for fall board meetings & other presentations later this year, regarding making changes required by new accounting standards & new tax regulations

TODAY’S WEBINAR

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• FASB pronouncements
• Revenue recognition (ASC 606)
• Leases (ASC 842)
• Other accounting changes
• Tips for early adopters of ASU 2016-14
• Tax challenges & tips
• Impact of GASB standards
• GASB to be implemented
• Pension (year 2 & 3 – GASB 73, 78, 81))
• OPEB reporting (GASB 74)
• Split Interest Agreements (GASB 81)
• Lease exposure draft
• SFA (Perkins closeout & audit findings)

AGENDA

• Revenue recognition (ASU 2014-09) – effective for years beginning after

December 15, 2017, (FY19) for Conduit Bond Obligors or a year later for everyone else: practically speaking, need to consider the following issues

FASB PRONOUNCEMENTS – REVENUE RECOGNITION

IMPACT COMMUNICATION IMPLEMENTATION HOW TO FIND ANSWERS

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Communication needs of boards, management & accounting & finance staff

• How the new standard will impact revenue streams
• Contributions – scoped out
• Tuition – including traditional & nontraditional programs
• State or federal appropriations (contract with a customer or

contribution?)

• Sponsored contracts (including disclosure requirements)
• Sponsored grants

FASB PRONOUNCEMENTS – REVENUE RECOGNITION IMPACT

Mainly Larger Mainly Larger Schools Mainly Larger Schools

Communication needs of boards, management & accounting & finance staff

• How new standard will impact revenue streams
• For institutions with health care entities
• Patient services – transaction price, performance obligation, impact of collectability
• Clinical trials – transaction price, performance obligation
• Royalties & licensing – point in time vs. over time, variability, handling of

expenses under contract

• Auxiliaries (housing, dining contracts, bookstore including warranty obligations

& rights of return & athletics)

• Publications
• Other (conferences, memberships, corporate sponsorships)

FASB PRONOUNCEMENTS – REVENUE RECOGNITION IMPACT

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Revenue Stream Accounting Impact Data/System Impact Disclosures

• 1. Tuition
• 2. Continuing Ed/Online
• 3. State/Federal

Appropriations

• 4. Sponsored Contracts
• 5. Sponsored Grants

TBD TBD TBD

• 6. Contribution Revenue

FASB PRONOUNCEMENTS – REVENUE RECOGNITION IMPACT

High Impact Moderate Impact Low Impact Scoped Out

Color Code

FASB PRONOUNCEMENTS – REVENUE RECOGNITION COMMUNICATION

Board Management Finance Teams

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Communication needs of boards, management & accounting & finance staff

• Boards – what do I tell them?

FASB PRONOUNCEMENTS – REVENUE RECOGNITION COMMUNICATION

Major Areas of Change Magnitude of Change Probable Direction of Change Timing of Implementation

FASB PRONOUNCEMENTS – REVENUE RECOGNITION COMMUNICATION

Major Areas of Change Magnitude of Change Probable Direction of Change Timing of Implementation

Timeline for implementation steps (applies to FYE May or June 30, 2019, for conduit debt issuers, or FYE May or June 30, 2020, for all others) New areas for internal control (existence, completeness, valuation, rights & obligations, etc.) Areas for estimates & judgments (allocation of transaction price, collectability, etc.) New vocabulary (contract with a customer, transaction price, performance

• bligation, consideration payable to customer, right to withdrawal)

Board Communication Management Communication

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FASB PRONOUNCEMENTS – REVENUE RECOGNITION COMMUNICATION

Finance Staff Communication

• Inventory process for all material revenue streams & existing contracts
• Implement the five-step approach for all material revenue streams
• Identify new estimates & judgments. Accumulate, organize & document relevant supporting

conclusions & calculations

• Determine transition model – run parallel (two years prior to implementation) under full

retrospective or for “modified approach” – use current GAAP two years prior & disclose impact on each line item in year of implementation

Management Communication Board Level Communication

• Finance staff communication plan – additional matters
• Process for collecting data for disclosures
• Systems changes or adjustments needed
• Pro forma impact (especially related to ratios & debt covenants)
• Format PBC workpapers to be evaluated by auditors who will be

evaluating the implementation of this standard

FASB PRONOUNCEMENTS – REVENUE RECOGNITION COMMUNICATION

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REVENUE RECOGNITION IMPLEMENTATION PLAN HOW TO FIND ANSWERS

• Resources
• AICPA Revenue Recognition resource page
• AICPA publication: “Financial Reporting Brief: Roadmap to

Understanding the new Revenue Recognition Standard”

• Center for Audit Quality: Preparing for the New Revenue Recognition

Standard

• BKD Summary of AICPA Progress on Revenue Guidance (March 2017)

bkd.com/thought-center

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• Leases (ASU 2016-02): effective for years beginning after December 15,

2018, (FY20) for Conduit Bond Obligors or a year later for everyone else. Practically speaking, need to consider the following issues

FASB PRONOUNCEMENTS – LEASES

IMPACT COMMUNICATION IMPLEMENTATION HOW TO FIND ANSWERS

Communication needs of boards, management & accounting & finance staff

• How the new standard will impact
• Debt covenant & debt capacity assessments
• Financial ratios
• Bond ratings & cost of borrowing
• Institutional budgeting
• Procurement & contract review

FASB PRONOUNCEMENTS – LEASES IMPACT

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FASB PRONOUNCEMENTS – LEASES COMMUNICATION

Board Management Finance Teams

Communication needs of boards, management & accounting & finance staff

• Boards – what do I tell them?

FASB PRONOUNCEMENTS – LEASES COMMUNICATION

Major Areas of Change Magnitude of Change Probable Direction of Change Timing of Implementation

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FASB PRONOUNCEMENTS – LEASES COMMUNICATION

Major Areas of Change Magnitude of Change Probable Direction of Change Timing of Implementation

Board Communication Management Communication

• Review of contracts for lease determination
• Includes contracts that could include leases
• Review of impact (if any) on debt covenants
• Review of impact on Title IV compliance ratios
• Communication with rating agencies
• Policy level decisions (materiality, etc.)

FASB PRONOUNCEMENTS – LEASE COMMUNICATION

Finance Staff Communication

• Inventory process for all contracts including those that could have embedded leases
• Transition options including practical expedients
• Identify new estimates & judgments. Accumulate, organize & document relevant supporting

conclusions & calculations

• Calculation tools to use (existing ERP tools, commercially purchased software, etc.)
• For larger, more complex entities think about & decide upon procedures for data collection &

coverage of completeness assertion

Management Communication

Board Level Communication

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HOW TO FIND ANSWERS

• Resources for software*
• LeaseAccelerator
• SAP Lease Administration by NAKISA
• Aptitude Lease Accounting Engine
• Financial Computer Systems, Inc.: EZ13
• Real Asset Management

*No endorsement implied

A FEW OTHER FASB ACCOUNTING CHANGES

*May 10, 2017 – FASB EITF Project added to determine accounting for costs associated with implementing cloud computing

Accounting Change Impact Effective Date – Public Entity Effective Date – Nonpublic Entity Fees paid in a cloud computing arrangement* Guidance to determine if cloud computing includes a software license Years beginning after December 15, 2015. Generally FY June 30, 2017 (conduit debt) Years beginning after December 15, 2016. Generally FY June 30, 2018 Presentation of going concern (ASU 2014-15) Defined management’s responsibility to evaluate going concern & to provide disclosures Effective for annual periods ending after December 15, 2016 Effective for annual periods ending after December 15, 2016 Eliminating extraordinary & unusual Items Eliminates separate classification & disclosures for extraordinary items Effective for annual periods beginning after December 15, 2015 Effective for annual periods beginning after December 15, 2015

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OTHER FASB ACCOUNTING CHANGES

• For a full review of all FASB pronouncements impacting the 2017

fiscal year, please see “BKD FASB Standard Setter Update: 2016 Edition”

• Plan & implement early to avoid the “rush” of implementing

revenue recognition, leases & financial reporting for not-for- profits in sequential years. Notice the convergence of effective dates below

TIP FOR EARLY ADOPTERS OF ASU 2016-14

FASB Standard Schools w/Conduit Debt All Other Schools Lease FY20 FY21 Revenue Recognition FY19 FY20 Financial Reporting FY19 FY19

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• Nicole Fishback
• 990 compliance, form changes, due dates
• 1098T update
• UBI update
• Endowment issues
• Future issues

TAX CHALLENGES & TIPS

• Understanding IRS terminology in forms & instructions
• Hours involved in gathering data from multiple parties
• Lengthy process from end of fiscal year to actual filing return
• Overall tax compliance burden is usually higher than compared

to a for-profit entity

• Trying to ensure responses throughout the forms are consistent

CHALLENGES IN FORM 990 COMPLIANCE

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2017 FILING SEASON – DUE DATES

Tax Type (Form) Form No. Current Due Date New Due Date Current Extended Due Date New Extended Due Date Partnership 1065 4/15 3/15 9/15 9/15 S Corp 1120S 3/15 3/15 9/15 9/15 C Corp 1120 3/15 4/15 9/15 9/15 (Until 2025) 10/15 (After 2025) Trust 1041 4/15 4/15 9/15 9/30 Employee Benefit Plans 5500 7/31 7/31 10/15 11/15 Tax-Exempt Organizations 990/990-T 5/15 5/15 8/15 (First) 11/15 (Second) 11/15 FinCEN 114 6/30 4/15 None 10/15

Note: due dates listed are for entities with calendar year-ends

Due date changes for years beginning after December 31, 2015

• Changes to 2016 Form 990
• For tax years beginning after December 31, 2015
• First extension for Form 990 & 990-EZ will cover a six-month period
• Second extension is no longer available
• Previously, two three-month extensions were available
• The final filing due date with extensions remains unchanged

2016 FORM 990 CHANGES

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• Changes to 2016 Form 990
• The publicly supported charity definition has been updated to include

agricultural research organization under §170(b)(1)(A)(ix)

• Only pertains to §501(c)(3) organizations that are exempt as a public charity &
• perate as agricultural research organizations. In other words, it doesn’t affect

most organizations

2016 FORM 990 CHANGES

• Changes to 2016 Form 990
• Goods or services with insubstantial value have been indexed for
• inflation. The value of items valued at $10.60 or less that bear the
• rganization’s name or logo & are given to donors in exchange for a

donation of $53.00 or more need not be disclosed to the donor

2016 FORM 990 CHANGES

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• Proposed regulations issued on August 15, 2016
• Eliminate exceptions for reporting for nonresident aliens, individuals

whose tuition is fully paid by scholarship & individuals whose tuition is paid by a formal billing arrangement

• Announcement 2016-42
• Provides schools will not be assessed penalties if they report tuition

billed (box 2) instead of amount received (box 1) for calendar year 2017, which will be reported in 2018

FORM 1098-T UPDATES

• Terrell v. Commissioner, T.C. Memo 2016-85
• IRS disallowed the taxpayers education credit
• School had reported the amount billed rather than the amount paid on

the Form 1098-T

• Tax court sided with the taxpayer & allowed the credit
• The pertinent number is qualified tuition paid

FORM 1098-T UPDATES

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UBI UPDATES

• UBI is
• Income from a trade or business;
• Income from an activity that is regularly carried on; &
• Income from an activity that is not substantially related to the

performance of its exempt purpose or function

• Income & expenses are reported annually on Form 990-T

UBI UPDATES

• Private Letter Ruling 201644019
• IRS issued several rulings related to proposed activities of a section

501(c)(3) educational organization, specifically, that

• One-time sale of assets to partnership will not be treated as “regularly carried
• n” for UBI purposes;
• Payments by partnership to organization will be treated as exempt royalties

under section 512(b)(2);

• Lease payments made by partnership to organization will be excludable rent

payments under section 512(b)(3); &

• Activities of organization’s wholly-owned, for-profit corporate subsidiary will

not be attributed to organization

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• Technical Advice Memorandum 201633032
• IRS holds catalog & online retail sales are taxable
• IRS concludes income from various merchandise sales made through a

§501(c)(3) organization’s printed catalog, online store & various retail

• utlets were taxable as UBI because sales did not contribute

significantly to organization’s exempt purpose. Interestingly, the IRS seems to have abandoned its normal product-by-product UBI analysis in this ruling & instead made a blanket conclusion all sales are taxable

UBI UPDATES

• Common question – can school claim a loss from the conduct of

an unprofitable unrelated trade or business activity?

• IRS has disallowed college & university unrelated business

income tax loss deductions claimed on Form 990-T because years of continuous losses from the activity demonstrate the lack

• f a profit motive
• Two recent cases …

UBI UPDATES

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• In Roberts v. Commissioner, the Seventh Circuit reversed the Tax

Court, which had held that an individual did not operate his horse racing business with the intent to earn a profit

• The case contains a good analysis of the different profit motive

factors in §1.183 as well as discussion of the extent to which a profit motive can be found in business start-up activities

• http://media.ca7.uscourts.gov/cgi-

bin/rssExec.pl?Submit=Display&Path=Y2016/D04-15/C:15- 3396:J:Posner:aut:T:fnOp:N:1738162:S:0

UBI UPDATES

• In Main v. Commissioner, the Tax Court determined that an

attorney’s automobile restoration activity was engaged in with the intent to earn a profit, notwithstanding losses from the activity

• http://www.ustaxcourt.gov/UstcInOp/OpinionViewer.aspx?ID=10

843

UBI UPDATES

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UBI UPDATES

• Advertising or qualified sponsorship payments?
• IRS Tax-Exempt & Government Entities Divisions issued detailed analysis of

difference between taxable advertising income & qualified sponsorship payments that are not subject to UBIT

• Issue indicators in the contract for sponsorship payments
• Sponsor received any substantial return benefit
• Payment entitles the payor use or acknowledgment of the name or logo of the payor’s

trade or business in periodicals

• Payment is made in connection with any qualified convention or trade show activity
• Exclusive provider arrangement exists
• Advertising

COLLEGE & UNIVERSITY ENDOWMENTS

• In December 2015, Congressional Research Service published a report

describing possible changes to the federal income tax treatment of college & university endowments. There are ongoing congressional hearings on the subject

• Four areas of possible tax reform
• Imposing a minimum payout rate on endowments
• Imposing a tax on endowments or endowment earnings
• Limiting the charitable contribution deduction for certain gifts made to endowments
• Changing the tax treatment of certain offshore investment strategies that use

“blocker corporations” in connection with unrelated business income tax planning

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INVESTMENTS BY CRT IN ORGANIZATION ENDOWMENTS

• Many organizations are both trustees & charitable beneficiaries of

charitable remainder trusts (CRTs)

• Many donors & organizations invest CRT assets in the organization’s

endowment

• Many endowments though, earn UBI, & if CRT earns any UBI, it must

pay penalty excise tax equal to 100 percent of the amount of UBI

• PLR 201636043 – IRS concluded that redemption of the units would be

treated as gain or loss from investment activity & not characterized as UBI

LOOKING TO THE FUTURE

• Numerous individual & business “extenders”

expired on December 31, 2016

• Impossible to predict tax reform at this point
• Likely to require bipartisan support
• Unclear if tax legislation would be retroactive to

January 1, 2017

• Several drafts contain provisions on charitable

contributions

• Fate of recent treasury regulations

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Standard Description Effective Date GASB Statement No. 73, Accounting and Financial Reporting for Pensions and Related Assets That Are Not within the Scope of GASB Statement 68, and Amendments to Certain Provisions

• f GASB Statements 67 and 68

Issued June 2015 Related Resources: GASB Issues Final Rules Governing Reporting for Postemployment Benefits Other Than Pensions Establishes accounting & financial reporting requirements for defined benefit pensions & defined contribution pensions under plans not administered through a trust that meet specified criteria, i.e., not covered by Statement 68. The requirements are similar to Statement 68, with as-needed modifications for any assets

• accumulated. The standard also

provides minor changes to Statements 67 & 68 Amendments to Statements 67 & 68 & presentation requirements for assets accumulated for pensions not administered through a trust are effective for fiscal years beginning after June 15, 2015 The pension provisions are effective for fiscal years beginning after June 15, 2016 Applicable for June 30, 2017 year ends

GASB STANDARDS

Standard Description Effective Dates GASB Statement No. 78, Pensions Provided through Certain Multiple- Employer Defined Benefit Pension Plans Issued December 2015 Related Resources: GASB Finalizes Guidance on Certain Cost-Sharing Pension Plans Narrows the scope & applicability of GASB Statement No. 68, Accounting and Financial Reporting for Pensions, to exclude pensions provided to employees of state or local governmental employers through a cost-sharing multiple-employer defined benefit pension plan that meets specific criteria. Establishes new guidance for these employers, including separate requirements for recognition & measurement of pension expense or expenditures & liabilities, note disclosures & required supplementary information (RSI) Reporting periods beginning after December 15, 2015 FYE June 30, 2017

GASB STANDARDS

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Standard Description Effective Date GASB Statement No. 79, Certain External Investment Pools and Pool Participants Issued December 2015 Related Resources: New Amortized Cost Guidance for Investment Pools Establishes new criteria to continue amortized cost accounting for certain external investment pools & adds disclosure requirements for qualifying pools & their participants Reporting periods beginning after June 15, 2015. Certain portfolio quality & monthly shadow pricing provisions are effective for reporting periods beginning after December 15, 2015 December 31, 2016 & June 30, 2017 year ends

GASB STANDARDS

Standard Description Effective Date GASB Statement No. 74, Financial Reporting for Postemployment Benefit Plans Other Than Pension Plans Issued June 2015 Related Resources: GASB Issues Final Rules Governing Reporting for Postemployment Benefits Other Than Pensions Addresses the financial reporting for Other Postemployment Benefits (OPEB) defined benefit & defined contribution plans administered through trusts meeting specified criteria, requiring a statement of fiduciary net position & a statement of changes in fiduciary net position. In addition, the guidance requires more extensive note disclosures & RSI related to the measurement of the OPEB liabilities for which assets were accumulated. Also provides guidance on reporting OPEB assets not in a trust. Fiscal years beginning after June 15, 2016 FYE June 30, 2017

GASB STANDARDS

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Standard Description Effective Date GASB Statement No. 81, Irrevocable Split-Interest Agreements Issued March 2016 Related Resources: GASB Finalizes Irrevocable Split-Interest Agreements Guidance Standardizes recognition & measurement for various split-interest agreements. Governments receiving resources from an irrevocable split-interest agreement as the agreement’s intermediary would recognize assets, liabilities & deferred inflows of

• resources. Governments with a beneficial

interest in a split-interest agreement administered by a third party would recognize an asset & a deferred inflow of resources Reporting periods beginning after December 15, 2016 Calendar 2017 years & FYE June 30, 2018

GASB STANDARDS

Standard Description Effective Date GASB Statement No. 82, Pension Issues – an amendment of GASB Statements No. 67, No. 68 and No. 73 Issued March 2016 Related Resources: Final Guidance

• n Pension Implementation Issues

Addresses the presentation of payroll- related measures in RSI, selection of assumptions & treatment of deviations from guidance in Actuarial Standards of Practice for financial reporting purposes & classification of payments made by employers to satisfy plan member contribution requirements. In addition, GASB No. 82 updates or supersedes related questions in Implementation Guide No. 2015-1 Reporting periods beginning after June 15, 2016, with certain exceptions pertaining to the assumption guidance FYE June 30, 2017

GASB STANDARDS

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Topic & Title Description Status (Subject to Change) Exposure Draft: Leases Issued in January 2016 Related Resources: GASB’s Proposed Lease Accounting Changes Based on the foundational principle that all leases are financings of the right to use an underlying asset, the proposal recommends a single approach to accounting for leases. Lessees would recognize an intangible asset & lease liability, & lessors would recognize a lease receivable & deferred inflow of resources Final Statement: May 2017 Tentatively effective for reporting periods beginning after December 15, 2018. Earlier application is permitted Calendar 2019 or FYE June 30, 2020

GASB STANDARDS – EXPOSURE DRAFT

• If a student receives disbursement of a Perkins loan after June

30, 2017, & before October 1, 2017, for the 2017–2018 award year, the student may receive any subsequent disbursements of that Perkins loan. However, disbursements are not permitted after June 30, 2018

• Certain new disclosure requirements to borrowers
• Regarding end of future availability of Perkins loans
• Regarding Direct loan (DL) repayment & forgiveness benefits not

available to Perkins loans

PERKINS LOAN PROGRAM

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• Liquidation of Perkins
• A school’s Perkins loan portfolio & its Perkins loan revolving fund

must both be liquidated when it ends its participation in the Perkins loan program

• A school must liquidate its Perkins loan portfolio &

program fund, when it

• Voluntarily withdraws from the program;
• Has had its eligibility to participate in the Perkins loan program

terminated by ED;

• Has not been approved by ED for continued participation during

the school's recertification process; or

• Is closing

PERKINS LOAN PROGRAM – LIQUIDATION

• Perkins liquidation is
• Accounting for all the loans that remain in the portfolio, &
• Accounting for the remaining Perkins revolving fund
• What’s involved?
• Turn over loans to ED – assignment
• Account for all loans/update NSLDS accordingly
• Ascertain any liabilities as a result, e.g., purchased loans
• Split the remaining fund – distributional shares of remaining cash asset

PERKINS LOAN PROGRAM – LIQUIDATION

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• How to prepare?
• Assess your portfolio
• How many loans remain open?
• Are loans accurately being reported on FISAP?
• Are loans accurately being reported/updated to NSLDS?
• Discuss timing of liquidation
• Allowance for Perkins loans
• Liquidation audit

PERKINS LOAN PROGRAM – LIQUIDATION

• 1. Repeat Finding – Failure to Take Corrective Action
• 2. NSLDS Roster Reporting – Inaccurate/Untimely Reporting
• 3. Return to Title IV (R2T4) Calculation Errors
• 4. Return to Title IV (R2T4) Funds Made Late
• 5. Verification Violations

TOP AUDIT FINDINGS (ACCORDING TO DOE)

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• NSLDS Roster file (formerly called Student Status Confirmation

Report [SSCR]) not submitted in a timely manner to NSLDS

• Failure to provide notification of last date of attendance/changes

in student enrollment status

• Failure to report accurate enrollment types & effective dates
• Clearinghouse reporting schedule
• File submission or system issues

CAUSES OF TOP FINDINGS – NSLDS REPORTING

• Inadequate system in place to identify/track official & unofficial

withdrawals

• No system in place to track number of days remaining to return

funds

• Institutional charges incorrect
• Incorrect number of days used in term/payment period
• Incorrect number of days used for breaks
• Incorrect withdrawal date

CAUSES OF TOP FINDINGS – R2T4

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The information contained in these slides is presented by professionals for your information only & is not to be considered as legal advice. Applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor or legal counsel before acting on any matters covered. BKD, LLP is registered with the National Association of State Boards

• f Accountancy (NASBA) as a sponsor of continuing professional

education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org

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• CPE credit may be awarded upon verification of participant

attendance

• For questions, concerns or comments regarding CPE credit,

please email the BKD Learning & Development Department at training@bkd.com

CPE CREDIT

THANK YOU!

FOR MORE INFORMATION Nick Wallace | 317.383.4000 | nwallace@bkd.com Nicole Fishback | 317.383.4000 | nfishback@bkd.com

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