Report Right or It’ll Cost You (double)

Report Right or It’ll Cost You (double)

paper-stackReporting requirements for business just keep growing, and so do the penalties for doing it wrong.  New this year and just in time for the annual reporting season (makes it sound almost fun, huh?) are new forms to file and an increase in penalties for not making an effort to get the information correct and into the hands of the proper recipient. Failure to file by the due date can cost businesses $250 per item, up to $3,000,000 in penalties ($1,000,000 for small businesses).  Add to that the warning about intentionally not filing or having an “intentional disregard of the requirements to furnish a correct payee statement”, which carries a penalty of at least $500 per payee statement and has no maximum penalty. Clearly, the cost of making sure the information is correct and filed in a timely manner is far less than the cost of not getting it done – or done right.

Growing problems around wage and revenue reporting have caused the IRS to pursue a variety of measures over the years to try to improve information reporting.  The Affordable Care Act has also had quite an impact on wage and benefit reporting, increasing reporting requirements substantially.  From the introduction of health plan reporting on W2s to the new mandatory forms 1095-C and 1094-C (for applicable large employers), businesses of all sizes are feeling the pressure.

February 2016 marks the date when employers and healthcare providers are required to file those shiny new IRS information returns regarding employer-provided healthcare coverage, providing a copy of the return to each employee much like a W2. The information would then enable the IRS to enforce rules established under the Affordable Care Act by revealing whether an individual might be eligible for a premium tax credit, or if an employer may be subject to non-compliance penalties. Penalties for failing to comply essentially double in 2016.  And the IRS suggests that a “good faith effort” standard will be applied to information reporting, offering no relief for employers that fail to make the effort to file timely and correctly.

It wasn’t very long ago that 1099 filing requirements expanded substantially, forcing businesses to get far more detailed in their production of information to the IRS and to payment recipients.  While this filing requirement impacted businesses both large and small, most lived through it (with the help of their trusted accounting professional!) and were able to comply.  That effort informed the IRS on a wide variety of business payments and expenses not previously tracked, in particular payments made for services and non-employee compensation.

The increasing scrutiny of wage and earning information may also help in efforts to curtail tax refund fraud.  Identity thieves use stolen (or borrowed) social security numbers to file false tax returns early in the year. Unfortunately, with the IRS motto of “pay first, prove later” the cross checking won’t likely be done until after the refund check has been sent. Once the task is performed, however, the taxpayer could end up getting a letter from the IRS stating that more than one tax return was filed using the social security number, they owe for a tax year for which they did not file a return, or the IRS indicates that wages were reported from an employer the taxpayer doesn’t know.

The IRS expects tax refund fraud to top $21 billion by 2016, which is an increase of 223% from 2013 numbers. Tax refund fraud costs every taxpayer.  No wonder the IRS is getting tougher with the penalties for not filing information returns accurately or on time.

jmbunnyfeetMake Sense?

J

Following is the text from the IRS, which outlines the “Increase in Penalties for Failure to File Correct Information Returns and to Provide Correct Payee Statements — 31-JUL-2015

L. 114-27, section 806, increased penalties for failure to file correct information returns and provide correct payee statements for information returns required to be filed after December 31, 2015.

Penalties are discussed in Section O in the General Instructions for Certain Information Returns. The penalties in the bulleted list under “Failure To File Correct Information Returns by the Due Date (Section 6721)” are revised as follows.

  • $50 per information return if you correctly file within 30 days (by March 30 if the due date is February 28); maximum penalty $500,000 per year ($175,000 for small businesses).
  • $100 per information return if you correctly file more than 30 days after the due date but by August 1; maximum penalty $1,500,000 per year ($500,000 for small businesses).
  • $250 per information return if you file after August 1 or you do not file required information returns; maximum penalty $3,000,000 per year ($1,000,000 for small businesses).

Payment Card Roll Call: “Not Present” fraud likely to increase as EMV takes hold

Payment Card Roll Call: “Not Present” fraud likely to increase as EMV takes hold

rollingballNo retailer wants to become the next Target (pun intended).  Payment card fraud costs businesses and consumers billions of dollars every year.  What’s even more frightening, many of the breaches in the news are the result of innocent participants inadvertently granting access to the bad guys.  The Target breach in 2013 exposed the data of 110 million payment cards.  Hackers got into the network using perfectly good credentials of the HVAC company.  Sometimes password security just isn’t enough, which might bring in to question the security of all those SaaS subscriptions and online shopping sites folks use these days.

EMV chip technology, the standard around the world which has just recently become a standard in the United States, has done a lot to stem the tide of credit card fraud in other countries.  As it was implemented in various countries, guess where it pushed the fraudsters?  Where the anti-fraud technology wasn’t, of course! The United States was among the laggards in requiring EMV chip technology for payment cards, opening the door for bad guys and turning the US into a veritable haven for credit card fraud, “accounting for nearly 50% of global fraud losses, according to the Nilson Report[1]”.

EMV chip (or chip and pin) technology will go a long way to prevent credit card fraud for businesses accepting payment cards… in-person and counterfeit card fraud, anyway. Online retail, on the other hand, not so much.  A chip on the card doesn’t really help when the transaction is completed with the card not present (CNP).  Some industry analysts suggest that CNP fraud losses will exceed $6 billion within the next few years, making e-commerce and online payment security a high stakes game for even the smallest of retailers.  As it gets more difficult to hack the payment system when the card is presented, bad guys will fall back in even greater numbers to the card-not-present model to find their victims.

Online retailers and service providers must take additional steps to secure their systems and protect customers and business partners, and face the challenge with the understanding that effort must be ongoing as new threats emerge. Tokenization is a prime method of layering the system with security, making the merchant system somewhat less of a worthy target by not storing the card data in the system.  Even if the system becomes compromised, the bad guys wouldn’t find customer payment card information.  There are numerous other steps a business can take to secure the CNP sales, including applying behavioral analytics which might identify rogue activities, or using 3D Secure to authenticate a cardholder’s identity at the time of purchase.   The point is that CNP fraud is likely to spike as EMV technology takes a firm hold in the US.

Card fraud is already escalating rapidly for ecommerce retailers and other card not present channels – it didn’t take EMV to start on that roll but it will surely give it a push.  Paperless payment systems, SaaS subscription services and online application service usage are increasing dramatically and there’s no chip to get in the way of these transactions.  Sellers of any and every service utilizing online payments need to now pay particular attention to system and information security.  The risk has always been there, and EMV chips and other shifts in pay card technology simply give it a push.

jmbunnyfeetMake Sense?

J

 

[1] Chipping away at Credit Card Fraud with EMV; Information Week Tech Digest powered by Dark Reading, Nov 2015; NilsonReport http://www.nilsonreport.com/publication_newsletter_archive_issue.php?issue=1071

Accounting for Custom Manufacturing

Accounting for Custom Manufacturing

Accounting and bookkeeping is a part of every business large and small, yet there are myriad details to work with and a multitude of possible approaches to addressing the requirement.  From a summary perspective, there are standards which are fairly easily met, providing the basics of sales and expense tracking and income reporting sufficient for basic tax and compliance work to be performed.  Yet accounting may go much deeper into the operational processes of the business, delving into the details of productivity and profitability in order to find and expose areas where the business might improve both.

mfgManufacturing, particularly custom manufacturing or ETO (engineering to order) is among those industry types that could benefit tremendously from a more intimate and detailed approach to accounting.  Unfortunately, it is often difficult to find experienced professionals with not simply a competence in working with manufacturing industry sector clients, but specifically with ETO process.  Building to order is one thing, but finding the way to improve efficiency and profitability when every job is a custom encounter takes additional skills and a lot of data.  Accounting professionals with these skills are needed to help these custom manufacturers grow, transform their businesses and make the overall operations more efficient and sustainable.

It seems logical that manufacturing and ETO space businesses are ripe for the same bridging of technology and analysis that the accounting industry started broadly approaching some years back.  With bookkeeping processes being more frequently outsourced to non-accountants, the accounting professionals saw increased pressure to find more efficient ways of doing things and had to find new value to deliver to clients.  Technology, data collection and analysis became the foundations for delivering on that new requirement.  With the established model and philosophy, bringing more operational aspects of client systems into the mix and extending the model end-to-end just makes sense.

It takes a combination of systems – from the core accounting solution to the manufacturing control or other operational systems, through to the analytical tools.  Leveraging hosting technologies and cloud service, businesses are finally able to bring the multiple work locations – shops, warehouses and business offices – together in a single software and technology platform, and collect the level of detail necessary to provide a comprehensive and true picture of the business.  The analytical tools then provide the means to explore the details and identify where improvements might be made or where previously unrecognized risk exists.

QuickBooks desktop editions remain among the most popular financial systems used by manufacturing and job shop applications, largely due to the effectiveness of connecting the operational applications to an accounting solution which proves highly workable and which has strong industry support.  Even with the emergence of QuickBooks Online (and the push by Intuit to get customers to adopt this web-based alternative to desktop-based software) the QuickBooks desktop edition products continue to provide more functionality and application support for these working models, as the ability to fully manage the information in the solution exists more in the disk based products than it does in a multitenant web-based application.  Accounting “mechanics” are able to see, access and work with all the data rather than simply view reports where only half of the transaction is visible – making detailed accounting and data analysis more readily available.

 

The key is to leverage the accounting professional, the right software tools, and the platform and delivery environment that allows it all to work in concert for the entire organization.  Add the QuickBooks hosting service so the participants can work more closely together.  Enabling the accounting professional and bringing them closer to their clients (and client systems) allows the deeper move into operational issues, creating the basis for both to receive new and more value from the relationship.

jmbunnyfeetMake Sense?

J

 

 

EMV and Retail – Your Trusted Advisor Should Be Advising You about This

EMV and Retail – Your Trusted Advisor Should Be Advising You about This

EMVChipCardThere is ‘big change a comin’ for retailers, merchants and any business that accepts credit cards for payments, and there are a great many businesses that are completely unprepared for it.  The change, what is being referred to as the “Payment Networks’ Liability Shift”, goes in to effect in October 2015 and places the burden of liability for fraud squarely on the shoulders of the merchants and card issuers who are not compliant with certain payment system security standards.  Accounting professionals and Trusted Advisors – here’s one of those things you should be helping your clients with.  Help them get informed, trained, and prepared.  Help them to understand the risk and decide on a course of action.  This is part of what makes a trusted advisor: they got your back.

The way things generally work in the US today, a fraudulent charge on a credit card is likely to end up being covered by the credit card company (the issuer). Starting in October, retailers are supposed to be able to accept payment cards with EMV chips (named for the founders of the standard: Europay, MasterCard and Visa), and must process those cards using the compliant technology that takes advantage of what the chip processing and security offers.  If these conditions aren’t met – like having a POS or payment terminal not capable of reading the EMV chip – the merchant is on the hook for the fraudulent transaction.  Given the volume of credit card and payments fraud in the country you’d think that most merchants would already be ready for this, but replacing all the POS and terminal equipment could be pretty costly.  It may take a bit of analysis to understand the real risk and compare that to the cost of compliance.  Certainly it makes sense to always be in compliance, but there are always factors which influence how quickly (or how completely) compliance may be met.

The liability shift is part of the influence being leveraged to get businesses to adopt newer and more secure models of electronic payment acceptance and processing.  It is simply the case that the magnetic strip on a credit card isn’t good enough any longer.  The new EMV Chip reading payment terminals require that the card be inserted and processed by the terminal rather than simply swiping the magstrip across a reader.  Over 40 years of using the magstrip approach has helped to earn the United States a top spot on the leaderboard for credit card and financial fraud, and we seem to be lagging behind in adoption and implementation of the EMV technology even though it has been shown to seriously curtail fraud even as payment card usage increases.  The EMV chip process, which encrypts information about the card so that even the local POS system doesn’t get access to it, is far more secure and is being widely adopted and used in Europe, Canada, Latin America and the Asia/Pacific regions.  Now the clock is ticking for US businesses to get ready to either update their systems or accept the liability for not doing so.

The shift in how payment cards are made and processed is simply one of many changes which will continue to occur as technology and human ingenuity continue to be applied in both good and not-so-good ways.  Recognizing that the pace of change is increasing, businesses must find ways to remain informed and prepare for those changes which will impact the business operation and sustainability.  This is among the essential roles the trusted advisor plays, and the current imperative simply underscores the growing need for such advisors by business large and small.

jmbunnyfeetMake Sense?

J

Revenue Recognition and closing the reporting GAAP

Revenue Recognition and closing the reporting GAAP

chartOne company earns what the other company spends.  This is business, and it seems like it would be pretty straightforward, accounting for the money coming in and the money going out.  But it is really not that simple when it comes to business finances and accounting for revenue.  With investor pressure to improve share prices and market pressures forcing greater competition, businesses have always sought out ways to make the performance look as good as possible – on paper even if not in reality.  It is this requirement to make the business look better than it may actually be that drives “innovation” in financial reporting, and encourages some companies to use whatever rules are available to mislead investors or paint a rosy picture for stakeholders.  When the balance is lost and financial reporting standards become so oblique as to allow regular and gross misrepresentation, it is time to change the standards.

There are numerous instances of fraud and scandal reported from the finance departments of big businesses, but instances of improper or misleading revenue recognition can happen in even the smallest of companies, and not necessarily on purpose.  It is important to understand that properly and accurately reporting business revenue and earnings isn’t done just for investor satisfaction, it is an essential part of describing business performance that any owner or manager must be able to rely on.

Generally Accepted Accounting Principles (GAAP) provide investors and business owners with some consistency in the financial statements they use to analyze company performance, but only minimally.  This is partly due to the fact that GAAP is based not only on some standards established by policy boards (the authoritative standards) but also on “generally accepted” standards, which are often not really standards at all but simply past practice that was found to be accepted.  Especially in the global economy where fewer businesses operate solely within traditional territorial boundaries – and where accepted reporting methods vary widely – having a single financial reporting standard has become more important than ever.

Make it so, Number One.

Now there are new rules from FASB (Financial Accounting Standards Board) and IASB (International Accounting Standards Board) which provide clear and detailed guidance for how businesses recognize revenues.  These rules are based on a consistently applied set of principles, no matter what sort of business is involved and regardless of where the business is located.

A focus of the new rules of revenue recognition centers on customer contracts, delving into the details of how earnings from those agreements should be recorded. Consider that many businesses combine multiple products and services into a single agreement, even though there may be several deliverables or milestones included.  This method of booking customer contracts allowed companies to report revenues they were not yet due as part of a total agreement, often resulting with inflated earnings reports.   Stakeholders would perceive that the company had reached one earning threshold, but the reality was something quite different and performance expectations were unmet.

“FASB and the International Accounting Standards Board (IASB) issued converged guidance on recognizing revenue in contracts with customers. The new guidance is a major achievement in the Boards’ joint efforts to improve this important area of financial reporting.”  http://www.fasb.org/jsp/FASB/Page/BridgePage&cid=1351027207987

The new rules force an additional level of discussion, including a full set of disclosure requirements that will provide more information about contracts with customers.  Businesses must identify each promised deliverable and attached revenue or earning component, which helps to better understand how the revenue may be earned (and recognized) as the business performs on the various obligations to the customer.

Just take a look at some big ERP companies and the lawsuits generated from problems and failures in delivery – problems that might have been more clearly identified to investors and stakeholders if the tie between product sales and services to be performed were more clearly described.  In many cases, these situations exemplify the revenue recognition reporting problem, where large customer contracts and license sales were fully booked and recognized even though implementation services milestones attached to those license sales remained undelivered.

“2010 – JDA Software (i2) – Dillard’s, Inc.:  Dillard’s had alleged i2 failed to meet obligations regarding two software-license agreements for which the department-store operator had paid $8 million.” http://www.zdnet.com/blog/projectfailures/erp-train-wrecks-failures-and-lawsuits/12055

For private companies, reporting periods beginning after December 15, 2017 must follow the new guidance.  It may seem like a long period of time – from the decision to apply the new rules to the effective date – but the number of businesses the new rules will impact is large.  The FASB made a decision to delay the effective date because of the broad scope of organizations affected and “the potentially significant effect that a change in revenue recognition has on other financial statement line items.”

Business owners and their accounting professionals need to make sure that financial systems and processes are up to the task and can track and produce the detailed reporting these new rules require. For investors and analysts, the new reporting rules and detailed information they generate will go a long way towards minimizing the impact of innovative revenue reporting practices, and will hopefully bring a new level of believability and usefulness to business financial reports.

Make Sense?

J