Economic relief

Article Dean Dorton

Congress has added an additional $3 billion to the provider relief fund pool. This is much less than the $35 billion recently proposed but will hopefully provide some relief to those who need it the most. The new legislation also requires the U.S. Department of Health and Human Services (HHS) to distribute at least 85% of unobligated PRF money through an application-based portal to providers based on their 2020 financial losses.

In addition to the new funding, the legislation included a requirement for HHS to define lost revenue as it did in their June FAQs. That definition included any lost revenue and allows hospitals and other providers to “use any reasonable method of estimating” its lost revenues. This change is significant for many providers who were already considering returning much of the provider relief funds they had received. The new legislation will also require HHS to establish a process to return funds to hospitals that surrendered them in response to the September lost revenue definition.

Another key related change for multi-hospital systems in the bill will allow hospitals to transfer PRF grants within a health system.

Hospitals are required to file reports in February 2021 on the PRF grants they spent in 2020. Any unspent funds must be used by June 30, 2021.

Other key provisions of the new bill for hospitals include:

  • A three-year continuation, through 2023, of the delay in scheduled cuts to Medicaid Disproportionate Share Hospital payments
  • A two-year delay in the planned 2021 increase in the required thresholds of value-based payment participation that physicians need to qualify for a Medicare bonus
  • An extension of an earlier suspension of the 2% sequester cut in Medicare payments, with the suspension now continuing from Dec. 31 to March 31, 2021
  • $284 billion for another round of Paycheck Protection Program (PPP) loans to support small business during the pandemic

Do you have questions about the new relief and how it impacts your organization? Contact your Dean Dorton advisor or info@deandortonstg.wpenginepowered.com.

Article Dean Dorton

  • Extends the $300 ($600 MFJ) above-the-line deduction for those taxpayers not itemizing deductions through 2021 and imposes a penalty for overstating contributions.
  • Extends the one year increased adjusted gross income limits on deductible charitable contributions for individuals who itemize deductions and corporations.

Payroll Protection Loan Program (PPP)

  • Expands the PPP eligibility to include certain qualified 501(c)(6) organizations. Qualified 501(c)(6) organizations are those that do not receive more than 15% of receipts from lobbying, lobbying activities do not compromise more than 15% of total activities of the organization, cost of lobbying did not exceed $1 million during the most recent tax year of the organization ending before 2/15/20, and the organization has fewer than 300 employees;
  • Expands forgivable expenses to include COVID-19 worker personal protective equipment, property damage costs, supplier costs, and technology and human resources expenditures;
  • Simplifies the forgiveness application to a one-page document for loans $150k or less by allowing a certification that they complied with the CARES Act PPP loan provisions;
  • Allows for-profit entities to deduct the expenses paid with loan proceeds and exclude the loan forgiveness from income;
  • Creates a second PPP loan program that is available to employers that
    • Had a 25% or more reduction in gross revenues or receipts between the same quarters in 2019 and 2020, and
    • That had 300 or fewer employees.
    • Maximum loan amount is $2 million.
  • Repeals reduction to loan forgiveness for those borrowers who also received an Economic Injury Disaster Loan (EIDL).

EIDL

Provides for a new round of EIDL funds for employers with 300 fewer employees, and have suffered an economic loss of 30% or more during 2020. Emergency grants are extended through 12/31/21.

Employee Retention Credit

The Act extends the availability of the credit for qualified wages paid through, and including, June 30, 2021, and makes several prospective enhancements. For calendar quarters beginning after December 31, 2020, the Act:

  • Increases the credit percentage from 50% to 70% of qualified wages;
  • Raises the limit on the amount of qualified wages that can be taken into account per employee from $10,000 for all calendar quarters to $10,000 per calendar quarter;
  • Expands eligibility for the credit by reducing the required gross receipts decline from more than 50% to more than 20% of gross receipts for the same calendar quarter in 2019;
  • Allows employers to elect to use prior quarter gross receipts to determine eligibility;
  • Permits certain governmental employers to claim the credit, including 501(c)(1) organizations, colleges and universities, and entities whose principal purpose or function is providing medical or hospital care;
  • Provides that “qualified wages” include only wages paid when an employee is not providing services for employers that averaged more than 500 (increased from 100) full-time employees in 2019;
  • Eliminates the 30-day rule for large employers;
  • Directs Treasury to issue rules allowing employers that averaged 500 or fewer full-time employees during 2019 to elect to receive an advance payment of the credit; and
  • Establishes rules to allow employers who were not in existence for all or part of 2019 to claim the credit.
  • The Act also makes a few changes to the Employee Retention Credit that are retroactive to the effective date of the CARES Act. The Act retroactively;
    • Eliminates the provision in the CARES Act that prohibited employers from claiming the credit if they received a PPP loan. (Note, however, that forgivable payroll costs for purposes of the PPP do not include qualified wages taken into account in determining the Employee Retention Credit); and
    • Clarifies the definition of “gross receipts” for tax-exempt organizations by reference to Internal Revenue Code Section 6033.
    • Provides that group health plan expenses can be considered qualified wages even when no other wages are paid to an employee.

Paid Sick and Family Leave Credit

  • Extends the refundable payroll tax credits through, and including, 3/31/21.
  • Does not extend the requirement to provide paid leave, which expires 12/31/20, but employers now have an opportunity to claim payroll tax credits for those wages.

Shuttered Venue Operators

Provides $15 billion to aid performance venues, independent movies theaters, and cultural institutions.

Do you have questions about the new relief and how it impacts your organization? Contact your Dean Dorton advisor or Allison Carter at alcarter@deandortonstg.wpenginepowered.com.

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Individual Provisions

Above-the-line Charitable Contribution Deduction – Under the CARES Act, non-itemizers were allowed a $300 above-the-line deduction for qualified charitable contributions made during 2020. The Act extends this deduction into 2021 and increases the amount for married couples filing a joint return to $600.

Increased Cash Contribution Limits – The increased limit for cash contributions made to qualifying charities during 2020 implemented by the CARES Act is extended into 2021. This means that for 2020 and 2021, there is no limit to cash contributions made to qualifying charities (i.e., individuals can deduct up to 100% of their adjusted gross income).

Health and Dependent Care Flexible Spending Arrangements (FSAs) –For 2020 and 2021, sponsors of FSAs may allow a 12-month grace period after the plan year-end for spending of unused funds, and an employee that ceases to participate in the FSA may use funds through the grace period.

Rebate Checks – A second round of rebate checks will be forthcoming. The Act provides for checks in the amount of $600 per eligible family member and will have the same phase-out range as the original rebates. The phase-out starts at $75,000 for single filers, $112,500 for heads of household, and $150,000 for married couples filing jointly. Eligible family members include dependents under 17 years of age. As before, an underpayment by the Treasury will be recouped on your 2020 return, but an overpayment will not have to be repaid.

Educator Expense Deduction – The $250 educator expense deduction now includes personal protective equipment as an eligible expense.

Child Tax Credit and the Earned Income Credit – For purposes of determining the refundable amount of both of these credits, a taxpayer may elect to use their 2019 earned income if it is greater than their 2020 earned income.

Business Provisions

Clarification of Tax Treatment of Covered Loan Forgiveness – The CARES Act provided that recipients of Paycheck Protection Program (PPP) loans may use the loan proceeds to pay certain business expenses; however, there was ambiguity about whether the expenses paid with the loan proceeds were deductible for tax purposes.

The Act clarifies that taxpayers whose PPP loans are forgiven are allowed deductions for otherwise deductible expenses paid with the proceeds of a PPP loan, and that the tax basis and other attributes of the borrowers’ assets will not be reduced as a result of the loan forgiveness.

Farmers’ Net Operating Loss Changes – The Act clarifies that farming net operating carrybacks remain eligible for the two-year carryback (versus the general five-year net operating loss carryback as authorized by the CARES Act). Additionally, those who previously waived the carryback period for farming net operating losses may revoke the waiver in order to file a net operating loss carryback claim.

Depreciation of Certain Residential Rental Property over a 30-year Period – The Tax Cuts and Jobs Act (TCJA) allowed real property trades or businesses to elect out of the business interest deduction limitations of Internal Revenue Code Section (“IRC Sec”) 163(j). In return, however, the electing taxpayer had to, for tax years beginning after December 31, 2017, treat nonresidential real property, qualified improvement property, and residential rental property as subject to the alternative depreciation system (the ADS). Also, the TCJA changed the ADS recovery period for residential rental property from 40 years to 30 years for property placed in service after December 31, 2017.

For tax years beginning after December 31, 2017, the Act assigns a 30-year ADS depreciation period to residential rental property even though it was placed in service before January 1, 2018 if the property is held by an electing real property trade or business and, before January 1, 2018, wasn’t subject to the ADS.

50% Limit on Business Meal Deduction Is Suspended for 2021 and 2022 – Taxpayers may generally deduct 50% of the ordinary and necessary food and beverage expenses associated with operating a trade or business. Under the Act, the 50% limit will not apply to expenses for food or beverages provided by a restaurant that are paid or incurred after December 31, 2020, and before January 1, 2023.

Disaster Relief Provisions

10% Early Withdrawal Penalty Does Not Apply to Qualified Disaster Distributions – A 10% early distribution penalty generally applies to, among other things, a distribution from an employer retirement plan to an employee who is under the age of 59½. The Act provides that the penalty does not apply to a qualified disaster distribution. A “qualified disaster distribution” includes certain distributions from an eligible retirement plan to an individual whose principal residence is located within a Presidentially-declared disaster area other than an area for which a disaster has been declared solely by reason of COVID-19.

Corporations Can Deduct “Qualified Disaster Relief Contributions” up to 100% of Taxable Income – In general, a corporation’s charitable deduction can’t exceed 10% of its taxable income. The 10% limit has been increased to 25% for 2020 and 2021.

The Act establishes a new category of “qualified disaster relief contributions,” for which corporations are allowed a deduction up to 100% of taxable income. Again, for purposes of this provision, a qualified disaster area does not include an area for which a disaster has been declared solely by reason of COVID-19.

Pension and Health Provisions

The Act adds a new IRC section which provides that group health plans must implement procedures to prevent surprise medical bills (i.e., bills from an out-of-network medical provider that a patient receives when an emergency or other issue forces the patient to use the out-of-network provider). This section is effective for plan years beginning on or after January 1, 2022.

Tax Extenders

The following extenders were made permanent as part of the Act:

Reduction in Medical Expense Deduction Floor – The Act permanently reduces the threshold for the medical expense deduction to 7.5% of adjusted gross income. Without this provision of the Act, the 7.5% threshold was set to revert to 10% in 2021. The permanent reduction in the medical expense deduction floor means that individuals will be able to deduct medical expenses not compensated by insurance or otherwise to the extent those expenses exceed 7.5% of adjusted gross income.

Energy Efficient Commercial Building Deduction – The Act makes the $1.80 per square foot deduction for energy efficiency improvements to commercial building systems (hot water systems, heating, cooling, ventilation and lighting) permanent.

Higher Education Benefits – After 2020, the Act eliminates the deduction for higher education expenses and replaces it with a higher threshold phase-out range for both the American Opportunity Tax Credit and the Lifetime Learning Credit.

The following extenders were extended through 2025:

The New Markets Tax Credit – The Act allocates $5 billion a year to the New Markets Tax Credit that helps provide equity investments into low-income communities. The Act also extends the carryover period for unused credits through 2030.

The Work Opportunity Credit – The Act extends the Work Opportunity Credit, geared to increase hiring among over 10 targeted groups, until the end of 2025.

Qualified Principal Residence Indebtedness Discharge – The Act extends, through 2025, the exclusion from gross income for discharge of qualified principal residence indebtedness. However, the maximum amount that may be excluded from income is reduced from $2 million to $750,000.

Empowerment Zone Tax Incentives – The Act extends tax benefits for certain businesses operating in Empowerment Zones through December 31,2025.

Exclusion of Certain Employer Payments of Student Loans from Employee’s Income – The CARES Act allowed employers to contribute up to $5,250 annually toward an employee’s student loan on a tax-free basis. The Act extends this provision, which was set to expire in 2021, through 2025.

The following extenders were extended through 2021:

Treatment of Mortgage Insurance Premiums as Qualified Residence Interest – The ability to deduct qualified mortgage insurance premiums as qualified residence interest has been extended through 2021.

Classification of Certain Race Horses as Three-Year Property – The Act extends the three-year depreciation recovery period for race horses two years old or younger to horses placed in service before January 1, 2022.

Energy Provisions

Personal Residences – The credit for energy efficient improvements to personal residences has been extended to December 31, 2021. Keep in mind there is a lifetime limit on this credit of $500.

Qualified Fuel Cell Motor Vehicle Credit – The Act extends the Qualified Fuel Cell Motor Vehicle Credit through 2021. The credit ranges from $4,000 to $40,000 depending on the vehicle purchased.

Residential Energy-Efficient Property Credit – This credit for purchase of qualified solar electric property, qualified solar water heating property, qualified fuel cell property, qualified small wind energy property, and qualified geothermal heat pump property was scheduled to phase-out after December 31, 2021. Under the new law, the phase-out will not occur until December 31,2023, and the credit percentage for 2021 has been increased from 22% to 26%. Thereafter, the credit will be 22%.

Do you have questions about the new law? Contact your Dean Dorton advisor, or contact us at:

insights@deandortonstg.wpenginepowered.com

Article Dean Dorton

The latest COVID-19 relief package passed by Congress has provided additional funding for Higher Education Relief. The package, titled the Consolidated Appropriations Act of 2021 (the “Act”), also included a new paycheck protection program and many other relief packages and tax changes. This article discusses the key components of the new higher education relief funding.

Colleges and Universities will receive an additional $23B to help relieve some of the impacts of the pandemic. The Act creates a new and complex formula for allocating these funds than what was used in the CARES Act, and it was difficult to immediately estimate how much each institution will get.

As with the CARES Act, institutions must distribute at least 50% of the funds received directly to students in the form of emergency grants. The remaining funds can be used for the following purposes:

  • Defray expenses associated with coronavirus (including lost revenue, reimbursement for expenses already incurred, technology costs associated with a transition to distance education, faculty and staff trainings, and payroll);
  • Carry out student support activities authorized by the HEA that address needs related to coronavirus; or
  • Provide financial aid grants to students (including students exclusively enrolled in distance education), which may be used for any component of the student’s cost of attendance or for emergency costs that arise due to coronavirus, such as tuition, food, housing, health care (including mental health care), or child care. In making financial aid grants to students, an institution of higher education shall prioritize grants to students with exceptional need, such as students who receive Pell Grants.

No funds received by an institution of higher education under from the Higher Education Emergency Relief Funds shall be used to fund contractors for the provision of pre-enrollment recruitment activities; marketing or recruitment; endowments; capital outlays associated with facilities related to athletics, sectarian instruction, or religious worship; senior administrator or executive salaries, benefits, bonuses, contracts, incentives; stock buybacks, shareholder dividends, capital distributions, and stock options; or any other cash or other benefit for a senior administrator or executive.

An institution that was required to remit payment to the Internal Revenue Service for the excise tax based on investment income of private colleges and universities under section 4968 of the Internal Revenue Code of 1986 for tax year 2019 shall have its allocation under this section reduced by 50 percent and may only use funds to provide financial aid grants to students or for sanitation, personal protective equipment, or other expenses associated with the general health and safety of the campus environment related to the qualifying emergency.

The Act also includes major changes to student financial aid including a simplification of FASFA form. There are also changes in how eligibility for Pell Grants is determined that should make it easier for lower-income students to receive the maximum amount of federal student aid.

As with the CARES Act, there will be mandatory reporting and audit requirements.

Do you have questions about the upcoming bill? Contact your Dean Dorton advisor, or contact us at:

insights@deandortonstg.wpenginepowered.com

Article Dean Dorton

The latest COVID-19 relief package passed by Congress extends two employer payroll tax credits—the employee retention credit and the credit for coronavirus-related paid sick and family leave. The package, titled the Consolidated Appropriations Act of 2021 (the “Act”), also expands eligibility for the employee retention credit to include employers that received a Paycheck Protection Program (“PPP”) loan. This article discusses the major changes to these credits that will take effect if the bill is signed by President Trump.

The Employee Retention CreditThe Back Story…

The employee retention credit is a refundable payroll tax credit created by the CARES Act, enacted in March. Currently, eligible employers can claim a credit against the employer portion of Social Security tax equal to 50% of “qualified wages” paid with respect to each employee. The amount of qualified wages that can be taken into account per employee for all calendar quarters is capped at $10,000 (for a maximum credit of $5,000 per employee). Under the CARES Act, the credit is available for wages paid after March 12, 2020, through and including December 31, 2020.

The CARES Act defines an “eligible employer” as any employer, including a tax-exempt organization, that was carrying on a trade or business during calendar year 2020 and meets one of the following economic hardship criteria:

  1. The operation of the business is fully or partially suspended during the calendar quarter due to orders from an appropriate governmental agency limiting commerce, travel, or group meetings because of COVID-19; or
  2. The calendar quarter is within the period that: (1) begins with the first calendar quarter after December 31, 2019, for which gross receipts are less than 50% of gross receipts for the same calendar quarter in the prior year; and (2) ends with the calendar quarter following the first calendar quarter for which gross receipts are greater than 80% of gross receipts for the same calendar quarter in the prior year.

The definition of “qualified wages” is more restrictive for employers that averaged more than 100 full-time employees during 2019 (“large employers”). For large employers, “qualified wages” include only wages paid when the employee is not providing services. In addition, “qualified wages” taken into account for an employee cannot exceed the amount the employee would have been paid for working an equivalent duration during the 30 days immediately preceding the period of the employer’s economic hardship (i.e., the “30-day rule”).

Employers that averaged 100 or fewer full-time employees during 2019 can count all wages paid during the period of economic hardship as “qualified wages.”

Allocable health plan expenses also can be treated as wages when computing the credit.

Importantly, the CARES Act provided that employers are not eligible for the employee retention credit if they received a PPP loan. Governmental employers, including the federal government, state and local governments, and governmental agencies and instrumentalities, also are not eligible.

For further details on the employee retention credit in the CARES Act, as originally enacted, click here.

The Act’s Major Changes

The Act makes several changes to the employee retention credit. Some of these changes are retroactive to the effective date of the CARES Act, while others apply going forward. Retroactively, the Act clarifies the definition of “gross receipts” for tax-exempt organizations by reference to the Internal Revenue Code. The Act also states that group health plan expenses can be considered qualified wages even when no other wages are paid to an employee. This change is consistent with previous guidance issued by the IRS.

Significantly, the Act retroactively eliminates the provision in the CARES Act that prohibited employers from claiming the credit if they received a PPP loan. The Act clarifies, however, that forgivable payroll costs for purposes of the PPP do not include qualified wages taken into account in determining the employee retention credit.

The Act extends the availability of the credit for qualified wages paid through and including June 30, 2021, and makes several prospective enhancements. For calendar quarters beginning after December 31, 2020, the Act:

  • Increases the credit percentage from 50% to 70% of qualified wages;
  • Raises the limit on the amount of qualified wages that can be taken into account per employee from $10,000 for all calendar quarters to $10,000 per calendar quarter;
  • Expands eligibility for the credit by reducing the required gross receipts decline from more than 50% to more than 20% of gross receipts for the same calendar quarter in 2019;
  • Allows employers to elect to use prior quarter gross receipts to determine eligibility;
  • Permits certain governmental employers to claim the credit, including 501(c)(1) organizations, colleges and universities, and entities whose principal purpose or function is providing medical or hospital care;
  • Provides that “qualified wages” include only wages paid when an employee is not providing services for employers that averaged more than 500 (increased from 100) full-time employees in 2019;
  • Eliminates the 30-day rule for large employers;
  • Directs Treasury to issue rules allowing employers that averaged 500 or fewer full-time employees during 2019 to elect to receive an advance payment of the credit; and
  • Establishes rules to allow employers who were not in existence for all or part of 2019 to claim the credit.

The Act requires Treasury, in coordination with the Small Business Administration (“SBA”), to conduct a public awareness campaign regarding the availability of the credit.

Tax Credits for Paid Sick and Family LeaveThe Back Story…

The Families First Coronavirus Response Act (“FFCRA”), enacted in March, requires most government employers, as well as tax-exempt organizations and private employers with fewer than 500 employees, to provide employees with paid sick or family leave for various COVID-19 related reasons. Under the FFCRA, the amount of leave and pay to which employees are entitled vary depending on the reason for leave.

To offset the cost of providing paid leave, the FFCRA provides employers with a refundable payroll tax credit equal to 100% of qualified sick and family leave wages, plus allocable health plan expenses and the employer’s share of Medicare tax, paid each calendar quarter. The credit is allowed against the employer portion of Social Security tax. Equivalent credits are available for self-employed individuals.

Under the FFCRA, the requirement to provide paid leave took effect April 1, 2020, and expires December 31, 2020. As enacted in March, the FFCRA provided that payroll tax credits for qualified sick and family leave wages were available for leave taken during this time period.

For more detail on the FFCRA sick and family leave tax credits, click here.

The Act’s Major Changes

The Act makes a handful of technical improvements to the FFCRA, including allowing self-employed individuals to elect to calculate the amount of the credit by using their average daily self-employment income from 2019 rather than 2020. However, the most significant change is an extension of the payroll tax credits to cover leave taken through and including March 31, 2021. Notably, the Act does not extend the requirement to provide FFCRA paid leave, which expires December 31, 2020. But, employers that provide paid leave to eligible employees from January 1 – March 31, 2021 now will have the opportunity to claim payroll tax credits for those wages.

Do you have questions about the upcoming bill? Contact your Dean Dorton advisor, or contact us at:

insights@deandortonstg.wpenginepowered.com

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Please Note: The Consolidated Appropriations Act of 2021 has passed both chambers of Congress, but it must be signed by the President before it becomes law. Late Tuesday, December 22, 2020, President Trump expressed unhappiness with the Act and requested that Congress make changes. Thus the information here is preliminary and subject to change in the event the bill is modified.

Sometime in the coming hours, it is expected that President Trump will sign into law the 2021 Congressional Appropriations Act (“Act”). The 5,593-page bill, rumored to be the longest bill ever passed by Congress, provides $900 billion in economic relief for individuals, small businesses, and others, as the country and its citizens continue to be mired in the personal and economic consequences of a global pandemic.

The Act covers a large number of topics, including extended unemployment benefits, economic stimulus payments, technical tax matters, emergency sick and family medical leave, and payroll tax credits. We will be providing additional details related to the Act over the next several weeks, but here is a brief summary of three provisions.

Income tax deductibility of expenses paid with Paycheck Protection Program (“PPP”) loans

Individuals and businesses, as well as their tax professionals, may breathe a collective sigh of relief as the Act includes a provision allowing full deductibility for income tax purposes of expenses paid with PPP loan proceeds. The provision is applicable to taxable years ending after the enactment date of the CARES Act, which was March 27, 2020.

The “New and Improved” PPP

In a section of the Act titled the “Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act,” over $284 billion is provided for businesses not receiving a PPP loan previously, and a “second draw” for first-round borrowers.

Generally, to qualify for a second draw, a business must have spent all of the proceeds of its first loan, have no more than 300 employees, and have suffered a 25% or greater quarterly reduction in gross receipts during 2020 compared to the same quarter in 2019. New organizations eligible for PPP loans include news organizations focusing on local news, destination marketing organizations, and certain Internal Revenue Code Sec. 501(c)(6) organizations.

Special consideration is provided for businesses in the accommodations and food services sector (NAICS 72 entities). For these organizations, the loan amount is calculated at 3.5 times the borrower’s average total monthly payroll costs whereas the loan amount is 2.5 times the borrower’s average total monthly payroll costs for non-NAICS 72 businesses. For all entities, the maximum loan amount for PPP loans is now $2,000,000 (rather than $10,000,000). Average monthly payroll costs may be determined based on calendar year 2019 or the one-year period before the date on which the loan is made, with special rules specific to seasonal applicants and recently started businesses. Publicly-traded companies are among those prohibited from receiving a second draw.

Rather than being bound by a definitive 8 or 24-week covered period, loan recipients may choose a covered period of 8 or 24 weeks or a duration in between. Also, the end date for round one loans has been extended from December 31, 2020 to March 31, 2021.

A simplified forgiveness application for PPP loans of $150,000 or less

There will be a one-page forgiveness application for loans not more than $150,000. SBA is instructed to create the form within 24 days from enactment of the Act. The form will require the borrower to provide the number of employees the borrower was able to retain because of the loan; the estimated amount of the covered loan spent by the borrower on payroll costs; and the loan amount. In addition, the borrower must certify that they accurately provided the required certifications and complied with the requirements of the program.

While the simplified process does not alleviate the potential for a loan review by the SBA, it does reduce the time period that loan documentation should be retained by the borrower. Borrowers should retain employment records for four years and all other records for three years, as opposed to the six years originally required.

Do you have questions about the upcoming bill? Contact your Dean Dorton advisor, or contact us at:

insights@deandortonstg.wpenginepowered.com